Alanya's Past, Present, and Future in Health Tourism

Alanya's Past, Present, and Future in Health Tourism

Alanya has always been a jewel of Turkish tourism with its unique nature, historical heritage, mild climate, and hospitable people. Offering a wide range of accommodation options, from family guesthouses to five-star hotels, Alanya caters to all tastes and today stands out not only as a holiday city but also as a health tourism center.

 

The Process from Tourist Health to Health Tourism

Tourism activity brings with it certain health risks. Sudden illnesses that may occur during holidays have given rise to the concept of "tourist health," and Alanya has become a model in this regard in Türkiye.

With over half a century of experience, our city has succeeded in providing fast, high-quality, and reliable healthcare services to foreign visitors thanks to the strong cooperation between private and public healthcare institutions.

This experience has, over time, laid the groundwork for health tourism and transformed Alanya from just a tourist destination into a "healthy living destination."

Dental Tourism: Alanya's First Step in Health Tourism

The roots of health tourism in Alanya can be traced back to the approximately 42,000 resident foreigners who have acquired property here and made the city their second home.

These individuals, especially those who received high-quality and affordable oral and dental health services in the field of dental tourism, confidently recommended them to others.

Thus, Alanya has become one of Europe's leading dental tourism centers with a natural reference chain.

Today, dental clinics in Alanya successfully offer advanced services such as implants, cosmetic dentistry, zirconium crowns, and teeth whitening not only to tourists but also to resident foreigners and their guests.

Alanya Shines in Medical Aesthetics, Fillers and Botox

In recent years, Alanya has gained remarkable momentum in the field of medical aesthetics. Clinics in Alanya specializing in mesotherapy, fillers, and Botox applications are preferred by international patients due to both their quality and price advantages.

Both resident expatriates and tourists on short holidays show high satisfaction rates with Botox clinics, mesotherapy centers, and aesthetic medicine treatments in Alanya.

Standards strengthened by Ministry of Health inspections have made Alanya a safe destination for medical aesthetics.

Today, doctors in the city offer services in Botox, fillers, PRP, mesotherapy, facial rejuvenation, and skin renewal that meet European standards.

Alanya has reached European standards in mesotherapy and filler treatments.

Mesotherapy centers in Alanya offer natural and lasting results to both local and international patients using state-of-the-art equipment.

The medical materials used in filler and Botox applications are fully approved by the Ministry of Health. Many clinics in our city have completed international accreditation processes and provide services at the same quality level as leading medical aesthetic chains in Europe.

Longevity and Healthy Living Camps: Alanya's Vision for the Future

Alanya has a strong future not only in terms of treatment tourism, but also in preventive health and wellness tourism.

In the coming years, it is predicted that boutique hotel models combining longevity, detox, breath therapy, smoking cessation, health camps, and spa-wellness concepts will rapidly increase.

Alanya's nature, climate, and balance of sea and forest perfectly meet the expectations of world tourists seeking "rejuvenation and healthy living on vacation."

Türkiye's Global Power in Health Tourism:

TÜRKİYE’NİN SAĞLIK TURİZMİNDE KÜRESEL GÜCÜ 

Organized in collaboration with Kırşehir Ahi Evran University and the International Health Tourism Institute, the International Health and Sports Tourism Congress is a significant event that brings together Türkiye's academic expertise, sector experience, and public vision in the fields of health and sports tourism on a single platform. This year, with strong participation from government institutions, universities, civil society organizations, and private sector representatives, the congress aims to contribute to shaping the scientific, economic, and managerial dimensions of the health tourism ecosystem around a shared vision.

Today, Turkey has transcended being merely a country offering services in health and sports tourism; it has become a powerful player setting global standards, gaining international trust through its quality medical services, and shaping the direction of the health tourism market. Our country is one of the few in the world capable of simultaneously producing and marketing every segment of health tourism. While reinforcing its identity as a provider of "medical excellence" with advanced medical procedures such as radical surgeries, oncological cases, and organ transplantations, it complements its service diversity with treatments based on individual preferences, such as hair transplantation, cosmetic surgery, dental tourism, and physical therapy and rehabilitation. This richness has made Türkiye not only a health destination but also a center of trust, quality, and sustainability.

Thanks to its geographical location, ease of transportation, climate conditions, and modern healthcare infrastructure, Turkey is among the leading countries in the world integrating health and tourism. When these advantages are combined with new trends that have gained momentum in recent years, models such as health hotels, long-life concepts, detox and wellness programs, and sanatorium centers are emerging. This new understanding of health tourism transforms treatment into an experience, offering individuals the opportunity for both physical and mental recovery.

Furthermore, Turkey is one of the world's leading countries in terms of thermal resource abundance. The integration of hot springs and spa centers with medical tourism has positioned our country in a unique place in tourism focused on both treatment and rejuvenation. Moreover, practices developed in geriatric tourism for individuals over 65 and disability-friendly tourism have transformed Türkiye's health tourism from merely an economic activity into an indicator of social inclusion.

We, as the Alanya Health Tourism Association, are also participating in this comprehensive organization. Our Vice President, Ahmet Girgin, will be giving a presentation titled "Global Perspective in Health Tourism Management: Understanding and Implementing Trends" in the "Innovative Approaches in Healthcare Management" session at the congress. The presentation will address current trends in the global health tourism market, competitive dynamics, and policies that will strengthen Türkiye's position on a global scale. Particular focus will be placed on topics such as digitalization, sustainability, international accreditation, and service exports.

Today, health tourism is not just an economic field; it is a multi-dimensional strategic sector encompassing diplomacy, public health, national brand management, and cultural interaction. Türkiye's investments in healthcare infrastructure in recent years, along with public-private sector collaborations, improved quality standards, and government-backed incentive models, have established international trust in the field of health tourism.

This congress is a gathering that strengthens the scientific, managerial, and strategic foundation of this entire process. The collaboration of academics, industry representatives, and public authorities will enable the determination of roadmaps for the future of health tourism through collective intelligence. In this context, we sincerely thank the Rector of Kırşehir Ahi Evran University, Prof. Dr. Mustafa Kasım Karahocagil, and the President of the International Health Tourism Institute, Dr. Fatih Seyran, and all stakeholders who contributed. We wholeheartedly hope that such organizations, which will enhance our country's international prestige in the field of health tourism and encourage scientific thinking and cooperation, will continue to increase. As the Alanya Health Tourism Association, we are proud to actively participate in every platform that supports the sustainable growth of our country's health tourism.

Alanya Health Tourism Association Supports a Shared Future

ALANYA SAĞLIK TURİZMİ DERNEĞİ’NDEN ORTAK GELECEĞE DESTEK

 

The Alanya Tourism Master Plan Workshop, held on October 16, 2025, in the conference hall of the Alanya Doğanay Hotel, marked a historic step for the future of the city. This workshop, which examined all aspects of tourism in the Alanya region, began with great enthusiasm, aiming to transform Alanya's potential into a more planned, participatory, and sustainable structure. This long-term process, lasting eight months, is being carried out under the coordination of the Alanya Promotion Foundation (ALTAV), with the support of Alanya Alaaddin Keykubat University, Alanya University, Alanya District Governorship, Alanya Municipality, Alanya Chamber of Commerce and Industry (ALTSO), Alanya Tourist Operators Association (ALTID), TÜRSAB, and numerous civil society organizations.

This workshop was more than just a meeting; it was a movement towards a shared vision that shaped the future of Alanya. With the participation of representatives from dozens of different sectors – including entertainment, sports, marine tourism, paragliding, ski slopes, transportation, health, and wellness – all components of tourism came together around the same table. Participants, each with experience in their respective fields, shared their views, proposed solutions, and future visions for tourism in sessions lasting several hours. This strong participation clearly demonstrated the maturity of Alanya's tourism culture and the willingness of local stakeholders to collaborate and produce results.

The scientific coordination of the meeting was carried out by Prof. Dr. Muharrem Tuna, President of the Tourism Academics Association. Prof. Dr. Burçin Cevdet Çetinsöz, Dean of the ALKÜ Faculty of Tourism, and Alper Gencelli, ALTAV project coordinator, also participated in this structure, which combined academic depth with field experience. Academics, bureaucrats, and sector representatives came together to redefine Alanya's tourism identity not only through past successes but also through future trends. The most important aspect of the study was that all participants were there voluntarily, not out of obligation. This spirit demonstrated that all stakeholders in Alanya are now acting with an understanding of collaborative development rather than competition.

As the Alanya Health Tourism Association, we actively participated in this process. Our president, Dr. Tevfik Yazan, and our board members were also present at the health tourism discussions, where we presented our ideas regarding the region's health tourism potential, shared our sectoral experiences, and presented our expectations for the future.

Today, we believe Alanya is a leading destination in health tourism; primarily in dental and aesthetic tourism, and in the future, we expect it to also lead the way in health hotels, wellness centers, and tourism for people with disabilities and geriatrics. In an era where new competitors emerge daily in global competition, we firmly believe that Alanya, a city renowned worldwide, will create a pioneering model in health tourism by integrating it with general mass tourism and collaborating with these strong stakeholders.

Türkiye's rise in health tourism over the last decade is rooted in a story that began much earlier in Alanya. Western European and Scandinavian visitors who settled in the region approximately thirty-five years ago received their first healthcare services here; by sharing their experiences with others, they essentially laid the foundations of health tourism in Türkiye in Alanya. Today, Alanya is once again leading the way, but this time by establishing a scientific, planned, and sustainable system.

The discussions at the health tourism table focused not only on current problems but also on future opportunities. Concrete goals were identified, such as the convergence of public and private sectors, joint action by health tourism NGOs, and the creation of a stronger structure through a clustering model for healthcare exporters. At the same time, the development of a destination strategy that can work in integration with projects like HİSER by the Ministry of Trade is important for Alanya's stronger positioning in the global health tourism market.

Alanya's location between two international airports, its strong healthcare infrastructure, and its long-standing relationship of trust with foreign patients make it one of Türkiye's most advantageous health destinations. In the coming period, it is anticipated that investments in health hotels, wellness centers, geriatrics and elderly care facilities, and tourism for people with disabilities will increase in the region. These investments will not only contribute economically but will also be part of a social transformation that strengthens Alanya's identity as a "healthy living city."

We sincerely thank everyone who contributed to this visionary work. Our deepest gratitude goes to the President of the Tourism Academics Association, Prof. Dr. Muharrem Tuna; the Dean of the Faculty of Tourism at Alanya Alaaddin Keykubat University, Prof. Dr. Burçin Cevdet Çetinsöz; Alper Gencelli, Board Member of ALTAV, who played a significant role in the implementation of this master plan and served as coordinator; and also to Dr. Vildan Yılmaz, who contributed to the health tourism clustering efforts, and to the Alanya Tourist Business Owners Association (ALTID).

The unity and synergy that Alanya traditionally demonstrates in every shared goal was felt most strongly in this project as well. The contributions of all our institutions, especially the Alanya District Governorship, Alanya Alaaddin Keykubat University, Alanya University, Alanya Chamber of Commerce and Industry (ALTSO), Alanya Municipality, and ALTAV, have once again shown that the greatest strength of this city is solidarity and collective wisdom.

As the Alanya Health Tourism Association, we are delighted to be a part of this valuable collaboration that serves regional development; we believe that this planned process, which brings together all stakeholders of tourism under a common goal, will create a strong model that will shape the future of Alanya.

This planned transformation, which begins in Alanya today, will usher in a new era on our country's tourism map tomorrow. And we are proud to be a part of this era.

Boundaries in Healthcare Redrawn: What are the Key Changes Made by the Omnibus Law?

SAĞLIKTA SINIRLAR YENİDEN ÇİZİLDİ:TORBA YASAYLA YAPILAN ÖNEMLİ DEĞİŞİKLİKLER NELERDİR?

The omnibus law dated July 21, 2025, which introduced changes in many areas of the healthcare sector, from service delivery methods and digitalization steps to physicians' working rights and advertising limits for private healthcare institutions, has initiated a restructuring process in the sector. Organizations working closely with health tourism, in particular, need to view these changes not merely as legal provisions, but also as strategic issues affecting their service models.

Doctors are allowed to work in a maximum of two private institutions.

One of the most notable amendments to the law came with the change to Article 12 of Law No. 1219 on the Manner of Practice of Medicine and Related Professions, dated April 11, 1928. Previously, physicians could work in "more than one" place; now, they are limited to working in "a maximum of two" private healthcare institutions. With an addition to the same regulation, physicians, dentists, and specialists, regardless of whether they have a public contract or not, can work in private healthcare institutions as insured employees under Article 4/a of Law No. 5510 on Social Insurance and General Health Insurance. This aims to prevent unregistered employment and makes it mandatory for institutions serving health tourism, in particular, to establish institutional and auditable structures in their physician employment. From the perspective of clinics, paying attention to insurance compliance in staffing planning and regulating the number of contracts has become not only a preference but also a legal obligation.

New Frontiers in Promotional Activities and Digital Content Restrictions

The restrictions imposed on promotional activities directly concern the visibility of healthcare services in digital environments. With the new paragraph added to Article 11 of the Basic Law on Health Services No. 3359 dated 7/5/1987, advertising activities exceeding the limits of promotion and information by private healthcare institutions are explicitly prohibited. According to the new regulation, a healthcare institution can only offer content limited to its address, contact information, working hours, specialties it accepts, academic and professional titles of its healthcare professionals, and preventive health information. Institutions engaging in activities that exceed these limits, are misleading, or create unfair competition will be subject to an administrative fine of up to 1 TP3T2 of their gross service revenue from the previous month, but not exceeding one hundred thousand Turkish Lira. This provision, which aims to prevent the marketing of healthcare services as a "product," necessitates a review of the content strategies of health tourism actors, especially those seeking to acquire patients through social media and digital advertising.

Fee and Auction System for Licenses and Permits

Yatırım süreçlerini ilgilendiren en önemli değişiklik ise MADDE 57 ile birlikte yürürlüğe girdi. Artık Sağlık Bakanlığı ve bağlı kuruluşlar tarafından verilen ruhsatlar, sertifikalar, permi belgeleri gibi dokümanlar için iki milyon Türk lirasını geçmemek üzere belirlenen tarifelere göre ücret alınabilecek. Ayrıca hastane açma veya belirli bir hizmeti verme hakkı sağlayan lisanslar açık artırma ile belirlenecek bedel karşılığında verilecek. Bu sistem, lisansların planlı şekilde dağıtılmasını sağlarken; sektöre girmek isteyen yatırımcıların mali planlamalarını daha öngörülebilir kılacak. Elde edilen lisans gelirlerinin %75’i, ülkemizin sağlık turizmini dünyaya tanıtmakla görevli olan Uluslararası Sağlık Hizmetleri A.Ş. (USHAŞ)’a aktarılacak.

Digitalization of Patient Consent Processes and the Era of E-Signatures

Another noteworthy point concerns the digitalization of patient consent processes. Thanks to a new paragraph added to Article 70 of Law No. 1219, patient consent forms can now be obtained electronically using biometric methods, mobile devices, or e-signature applications. This innovation particularly facilitates faster and more legally compliant digitization of consent documents for healthcare institutions conducting preliminary consultations with international patients. The procedures and principles of this system will be determined by the Ministry of Health, with the approval of the Information and Communication Technologies Authority (BTK). The imposition of a 250 TL administrative fine on healthcare institutions acting contrary to the regulation makes it mandatory for all institutions to increase their digital compliance in patient communication processes.

Overall Assessment

The regulations introduced by the new omnibus law are not only forcing the health tourism sector to comply with legal regulations; they are also pushing it to redefine its sectoral identity. The effects of these changes need to be considered not only from a legislative perspective, but also in terms of service strategies, patient relations, and international competitiveness.

From a positive perspective, making it mandatory for physicians to work within insured and institutional structures will reinforce the perception of "safe service" for international patients; this structure, supported by oversight, will raise ethical standards. Furthermore, the introduction of digital consent systems will offer a significant advantage in terms of speed and security, particularly in initial consultations with international patients.

However, these reforms may bring about some adjustment processes, especially for small and medium-sized clinics. Restricting physicians' right to practice to only two institutions may require careful and proactive planning, particularly in regions with a limited pool of doctors. Similarly, it is clear that the restrictions placed on promotional activities will change digital marketing habits. This may necessitate a reshaping of strategies for health tourism companies that have been communicating with patients through social media for years, while also paving the way for ethical, informative, and awareness-raising approaches in content production. Short-term fluctuations in patient numbers are possible during this transition period.

Granting licenses through a fee-based and auction-based system could create a significant financial barrier for new investors entering the market. At this point, it is inevitable that the sector makes this transition more sustainable with government support. Furthermore, channeling the generated revenues into health tourism through USHAŞ (Turkish Health Services Inc.), with proper planning, could strengthen the sector in the long term.

In conclusion, this omnibus bill is not merely a harmonization process; it is a process of "repositioning" in health tourism. Clinics need not only comply with the rules but also transform these rules into a foundation of quality. For regions like Alanya, which stand out in terms of health tourism, this period presents challenges in the short term, but offers opportunities in the long term in terms of reputation, quality, and sustainability. Seizing these opportunities will only be possible with the agility and vision of the sector stakeholders.

Click here to go to the website of the Official Gazette published on Thursday, July 24, 2025.

Click here to download the Official Gazette published on Thursday, July 24, 2025.

 

The law published in the Official Gazette

A Call for Awareness Regarding Health Tourism

SAĞLIK TURİZMİ ADINA DUYARLILIK ÇAĞRISI 

We are saddened to follow the allegations of "tourist insurance abuse" that have recently appeared in the local press and social media platforms, involving some healthcare facilities and hotels in the Alanya and Antalya regions. As the Alanya Health Tourism Association, we are not only a regional healthcare organization but also a non-governmental organization with a 10-year history that has actively contributed to many national and international health tourism processes.

Our association, since its establishment in 2015, has been working to ensure that healthcare institutions providing solutions to tourists' sudden illnesses, especially in mass tourism destinations, operate transparently, on a general basis, with high quality, and at fair prices, in the name of a country engaged in mass tourism. Furthermore, it aims to ensure that tourists experiencing sudden illnesses receive prompt healthcare services in both the public and private sectors, fostering a sense of security in Türkiye and contributing to the sustainability of Turkey's image as a shining example in the healthcare sector.

We have faced similar problems in the past. In particular, the high-coverage policies of Western European insurance companies have caused serious difficulties in the healthcare processes of tourists coming to our country, not only in the private sector but also in public hospitals. In 2015, the Ministry of Health transferred the "tourist health" processes carried out in public hospitals in coastal regions to a private company of Spanish origin. During this process, healthcare services provided in our public hospitals were billed to foreign insurance companies at very high prices, and some of our public hospitals were blacklisted by foreign insurance companies. As an association, we actively monitored the process at that time to stop these wrongful practices and made significant contributions to their termination.

The occurrence of such systemic problems even in public hospitals clearly demonstrates how vulnerable our healthcare services are to the unbalanced and uncontrolled effects of international insurance systems. This situation threatens not only the present but also Türkiye's future share of the health tourism market. Because in the future, the target audience for health tourism will no longer be limited to hair transplants, dental treatments, or cosmetic procedures; it will include the elderly population, cases requiring radical surgery, and oncological patients. This makes it difficult to establish a healthy, verifiable, and equitable relationship with international insurance companies.

Today, a similar structure poses a serious threat. The practice of treating health facilities within hotels as if they were revenue-generating commercial enterprises—like bathhouses, markets, tattoo studios, or car rental points—and renting them out to private hospitals, clinics, or practices at exorbitant prices, is completely contrary to the nature of healthcare. The marketing of these spaces through "pre-sale" before the season, and the demand by hotel managements for free healthcare services for themselves and their senior executives in return for these sales, are practices that cross ethical boundaries and lead to systemic corruption.

The fact that these facilities charge exorbitant amounts for services received in case of a sudden health problem, based more on economic expectations than medical necessity, undermines tourist trust and creates a breeding ground for the perception in European public opinion that "if you go to Türkiye, don't get sick."

Health tourism and mass tourism are now intertwined. If a tourist's access to healthcare services and their sense of security in the process are compromised, not only health tourism but also the overall tourism potential of our country will suffer directly. Unfortunately, the "Regulation on International Health Tourism and Tourist Health" issued in 2017 and the new regulation published on April 26, 2025, contain no definitions, rules, or control mechanisms for the activities of "assistant companies," which are among the most important actors in this field. Yet, this system has been actively operating in Türkiye for nearly 30 years.

We believe that the Ministry of Health urgently needs to cooperate with the Ministry of Tourism to make serious regulations on this matter. Tourist health and the relationship with assistance companies should be clearly defined and regulated in regulations with transparent, auditable, and enforceable rules.

Today, if these reports are true, criminal proceedings should be initiated swiftly; if false, the public should be clearly informed about these allegations that cast a shadow on regional tourism. We must demonstrate to both the domestic and international public that Türkiye is a determined, responsible country that does not compromise on ethical values in health tourism.

We thank Yeni Alanya Newspaper, a local media representative that contributes to the sector with its transparent, ethical and up-to-date approach to sustainable health tourism and safe tourism issues, for its sensitivity and wish it success in its work.

I bring this to the public's attention.

Kind regards.

Ahmet Girgin

Alanya Health Tourism Association

Vice President

A period of chaos has begun in health tourism with the new regulations.

26. 04. 2025

A period of chaos has begun in health tourism with the new regulations.

Ahmet GIRGIN

Alstud Vice President

Our observations in the destination where we live, starting with tourist health for nearly 20 years, the knowledge we have gained in all processes involving foreign patients along with tourist health services, our ten years of regional destination association activities, our national federation efforts and federation activities, our participation in the initial stages of Türkiye's first international health tourism fairs, and our presence among the first field teams working within the public sector in the field of health tourism have provided us with significant experience.

We come from a background that has been involved in creating health tourism mobility worldwide, through membership in NGOs in many countries, collaboration with more than ten global health tourism structures that organize their own health tourism fairs in the international arena, and most importantly, actively working with more than 200 international health insurance companies.

Following the regulation published in 2017, our association, as a civil society movement, and the federation it belongs to, organized regulatory workshops in cities such as Antalya, Adana, Bursa, and Konya, encompassing representatives from all sectors and inviting decision-makers. The resulting reports prepared by academics specializing in health tourism were repeatedly communicated to the relevant parties. After a long waiting period, a chaotic regulation finally emerged on April 26, 2025.

Historically, in the destination where we live, unplanned and unconsulted tourism segments developed, just as 30 years ago the tourism sector shifted from high-spending potential European tourists to lower-budget tourism branches; today, regulations in health tourism that are implemented without infrastructure, planning, and a disconnect from sector stakeholders carry the same risk.

The new regulation includes only three minor but significant changes that represent a tangible improvement for the sector. 

1. Removing the 5-Year Experience Requirement for Physicians Engaged in Health Tourism: Under the previous regulations, physicians were required to have at least five years of professional experience to provide services within the scope of health tourism.

However, while doctors who have graduated from reputable universities in Türkiye and possess diplomas approved by the Turkish Higher Education Council (YÖK) have the right to practice medicine freely within the country, it was neither fair nor logical that they were forced to wait an additional 5 years to serve foreign patients.

For example, a dentist could treat local patients and open their own practice, but if they wanted to serve foreign patients, they had to have five years of experience.

This situation led to the exclusion of young and qualified doctors from the system.

This flawed practice has been corrected in the new regulation, and the 5-year experience requirement has been removed, paving the way for the sector. We welcome this change.

2. Reducing the number of staff fluent in foreign languages to one in dental practices and small dental clinics: Under the old regulations, dental clinics or small-scale dental practices were required to employ staff fluent in at least two foreign languages in order to obtain a health tourism license.

This practice imposed equal conditions on all healthcare facilities, regardless of size.

For example, the same staffing requirements applied to a chain hospital with 1500 employees as to a small private practice with only 3 staff members.

This situation was severely harming small businesses.

The amendment to the regulation reduced this number to one, introducing a fairer and more reasonable arrangement for small businesses.

This change is an important step towards resolving an issue we have raised many times throughout the process.

3. Reducing the number of foreign language-proficient personnel in intermediary organizations from four to two: The previous regulation required health tourism agencies to employ staff fluent in four foreign languages.

However, while large hospitals (for example, those with international patient units of 200-300 people) were considered to have staff fluent in only two foreign languages, the requirement of four staff members for an intermediary agency that only provides referrals placed an excessive burden on the sector.

This situation was challenging the financial sustainability of intermediary institutions and hindering the sector's development.
With the new regulation, this number has been reduced to two, making it more realistic.

We consider this change a positive step for the sector and we thank you for it.

However, some new requirements introduced after all these improvements — particularly regulations such as the accreditation requirement, the mandatory integration into the HealthTürkiye portal, and the complication insurance system — pose structural risks for our sector.

While these initiatives might seem positive at first glance, a comparison with current field realities and international competitive conditions reveals them to be hollow and nearly impossible processes to implement.

Especially;

At this point, we would like to particularly emphasize the fact that these major structural changes, initiated after minor improvements, risk shrinking the sector rather than expanding it.

Now, let's examine in detail the short-term and long-term implications of the radical changes made in the new regulation.

1. Direct Acceptance of Health Tourists by Healthcare Institutions

➔ With the new regulation:
It has been stipulated that all healthcare institutions can accept international patients directly without intermediary agencies.

➔ Analysis
At first glance, this regulation appears to allow healthcare organizations to operate more quickly and independently. However, the critical role of intermediary organizations in the sector has been overlooked.

Intermediary organizations are not only structures that refer patients; they also manage processes such as international patient communication, accommodation, transfer services, cultural adaptation support, and emergency crisis management.
This service chain being carried out directly by healthcare facilities without professional support:
-Lack of coordination,
-Patient dissatisfaction,
-This will create serious risks, such as fluctuations in service quality.

2. Indirect Elimination of Travel Agency License

➔ With the new regulation:
Travel agencies, even if they are not classified as Group A travel agencies, have been able to provide accommodation and transfer services through an external travel agency with which they have a contract.

➔ Analysis
This regulation constitutes a clear violation of Law No. 1618 on Travel Agencies and the Association of Travel Agencies. While accommodation and transfer arrangements can only be made by authorized Group A travel agencies, bypassing this rule through indirect agreements will undermine legal certainty.

With this arrangement:

This will pave the way for healthcare institutions to organize accommodation/transfers through individuals or firms that do not have the legal authorization to do so.
Service quality will decrease.
This will create serious gaps in the protection of international patient rights.
More importantly, of the 1257 brokerage firms authorized to date;
All financial investments made to obtain a health tourism license,
The fees paid for authorization documents,
Investments and fees required to keep the business running,
It was considered completely null and void.

The investments that industry representatives had made over the years with hope for the future have suddenly been rendered invalid.

➔ Conclusion:
Unauthorized and unregulated service provision will increase in the sector, the motivation of professional organizations that have invested relying on state guarantees and regulations will be undermined, and the safety of both domestic and foreign patients will be threatened.

3. Mandatory Complication Insurance

➔ With the new regulation:
Healthcare facilities that perform surgical procedures in operating rooms are now required to have complication insurance.

➔ Analysis
Complication insurance is of great importance in terms of patient safety.
However, the current Turkish insurance market lacks comprehensive insurance products suitable for health tourism and compliant with international standards.

The mandatory insurance obligation introduced in this inadequate environment:
This will create new and significant costs for healthcare facilities.
This will create fertile ground for opportunism in an immature market for insurance companies.

Even worse, introducing a requirement to "issue policies only on the day of the auction" in an insurance system whose infrastructure is not yet in place will lead to the widespread use of policies with limited content, without proper risk analyses.

As a result, major crises are inevitable, such as a foreign patient experiencing complications being left outside the scope of insurance coverage, and this victimization being reported in the international press.
Such a loss of reputation would severely damage not only healthcare facilities but also our country's global brand value in health tourism.

➔ Conclusion:
Imposing mandatory insurance in an unprepared system will create uncertainty, injustice, and severe financial crises in the sector; potential patient suffering will seriously damage our country's reputation on the international stage.

4. Unchanging Problems in Tourist Health for 7 Years

➔ With the new regulation:
Despite being on the agenda since 2017, no concrete steps have been taken regarding tourist health services, and this area has been completely ignored in the new regulation.

➔ Analysis
Tourist health services are a crucial area of service that covers the treatment of illnesses, injuries, or other urgent medical needs of foreigners residing in the country.

This sector, even if not directly related to health tourism, directly impacts the international patient experience and the country's image.

However, the new regulation states:

No specific status has been defined for medical assistant firms providing health services to tourists.
Quality standards and auditing processes for these services have not been established, and no regulations have been put in place regarding the operation of international health insurance companies within Türkiye.

However, over the past 7 years, industry representatives, health tourism associations, academics, and field workers have submitted countless reports and proposed solutions on this issue.

Despite all these warnings, the health and safety of tourists has been completely disregarded.
Specifically, those who have been working in the field of health tourism for many years and:
Offering professional translation support for communication with foreign patients,
Managing communication between patients/hospitals/health insurance companies during times of crisis.

Medical assistance companies specializing in international patient processes,

Leaving it null and void without granting it any legal status creates a major weakness.

This deficiency:
The inability to protect tourists who are stranded in an emergency,
This has led to a decrease in the satisfaction scores of foreigners visiting our country.
This will cause permanent damage to Türkiye's reputation in the healthcare sector.

➔ Conclusion:
This lack of regulation in the field of tourist health risks leading to serious irregularities on the ground, a decrease in international patient dissatisfaction, and a long-term decline in health tourism revenues.

5. International Insurance Companies and the Neglect of Process Management

➔ With the new regulation:
The regulations governing the operation of international health insurance companies do not include any provisions regarding critical stages such as patient referral, payment guarantee, treatment approval, and process management.

➔ Analysis
A significant portion of health tourists coming to Türkiye today;
Private health insurance,
Travel health insurance.
They receive services through foreign health funds.

These insurance companies are the parties that directly manage the process in many stages, from patient admission to payment guarantee, treatment processes, and post-recovery follow-up.
However, the new regulation does not foresee any rules, obligations, or regulations regarding the operation of these insurance companies within Türkiye.

This situation;
This creates uncertainty in the payment collection processes of healthcare facilities.
This creates chaos in coordination between insurance companies and service providers.
This creates a situation where foreign patients suffer loss of rights and are victimized.
Disruptions, particularly in payment processes, will jeopardize the financial sustainability of healthcare facilities and damage the perception of professionalism in our country's health tourism sector.

➔ Result:
The lack of regulation of international insurance processes will weaken Türkiye's image as a reliable country in health tourism, create patient dissatisfaction, and lead to a long-term decline in the flow of international patients.

6. Mandatory Integration with HealthTürkiye Portal

➔ With the new regulation: All healthcare facilities and intermediary organizations are now required to register with the HealthTürkiye portal and conduct all their international health tourism processes through this portal.

➔ Analysis
While the goal of digitalization is important, this necessity disregards the unique digital infrastructures and branding efforts built over the years by nearly 7,000 healthcare facilities and intermediary organizations, and connects all international patient management processes to a centralized system.

However, the health tourism sector, by its very nature:
-Flexibility according to target markets,
- Specialized marketing techniques tailored to local needs,
-It requires unique digital solutions in line with international digital competition.
-This portal requires a mandatory connection.
-It will weaken the free competition environment,
-It will destroy corporate diversity,
-This will trap Turkey's health tourism sector in a bureaucratic structure.

In addition, the technical capabilities of the portal:
More than 6,000 healthcare facilities and over 1,000 intermediary organizations,

Whether the company has reached the maturity to simultaneously meet the needs of patient management, continuous data updating, and international communication is a serious question mark.

Forcing the standardization of successful healthcare institutions with unique digital strategies and flexible structures will weaken Türkiye's dynamic competitiveness in health tourism.

➔ Conclusion:
Mandatory integration into a single, centralized digital platform will lead to data uploading and process management problems in the short term, and in the long term, to inefficiencies, loss of diversity, and a decrease in international competitiveness in health tourism exports.

With the new regulation:

7. USHAŞ's Overload and the Reality of Supervision

The evaluation of healthcare facilities according to performance criteria, the collection of data flows, and the conduct of on-site inspection processes have been directly assigned to USHAŞ.

➔ Analysis
USHAŞ currently focuses on: Project development, International promotional organizations,
It is a public company that carries out activities such as health tourism support programs.
However, the performance audit and continuous field control responsibilities introduced by the new regulation require the employment of 350-400 expert personnel.

Sector-focused audit training requires mechanisms for developing audit and performance criteria.

USHAŞ's current capacity and infrastructure are not mature enough to handle such an intensive and technically complex inspection load.

Given this reality;
The inspections were superficial and incomplete.
Making subjective evaluations based on complaints,
The sense of fairness within the sector will inevitably be undermined.
In particular, the inability to conduct performance evaluation processes objectively, verifiably, and in line with the dynamics of the sector,

This will cause Türkiye to lose confidence in health tourism, diminish the motivation of healthcare facilities, and slow down investments.

➔ Conclusion:
The overloading of USHAŞ will undermine confidence in fairness in supervision within the sector, and in the long term, will lead to a loss of growth momentum in health tourism and a decrease in international competitiveness.

8. Accreditation Requirement

➔ With the new regulation:
Healthcare facilities that will engage in international health tourism activities are now required to obtain internationally valid accreditation certificates from specific accreditation bodies.

Analysis
Of course, improving the quality of service is an important goal for health tourism.
However, the accreditation requirement that has been introduced;
This will create a heavy financial burden for a large number of healthcare facilities in Türkiye.
Especially for medium-sized hospitals, medical centers, and dental clinics, access will become almost impossible.
International accreditation documents;
High consulting fees,
Required document renewals,
This requires fundamental changes in internal company processes.

This situation will lead to the exclusion of small and medium-sized healthcare facilities from the health tourism market.
In addition, there are significant uncertainties regarding the document issuance process defined in the new regulation:

TÜSKA The Turkish Institute for Healthcare Quality and Accreditation has stated that a new standard for health tourism will be prepared; however, it is unclear whether this standard already exists and whether its implementation principles have been determined.
It is not clearly defined whether the Ministry will issue the document or whether TÜSKA will prepare it directly.

There is no statement regarding the international validity of the document to be issued by TÜSKA; it is unclear whether the document will be based on a quality standard approved by a global accreditation body (such as ISQua) or whether it will only have national validity.

This highly uncertain environment makes operational planning impossible for both healthcare facilities and intermediary organizations.

As a result, the sector is being dragged into a chaotic process, far from clear rules and predictability.

➔ Conclusion:
Instead of improving quality across the sector, the accreditation requirement will push small and medium-sized healthcare facilities out of the system, leading to significant reductions in the diversity and service capacity of Türkiye's health tourism; at the same time, the lack of transparency and international compliance regarding the process will negatively impact the trust and investment environment.

In conclusion;

However, a look at the overall structure of the regulation clearly shows that it was hastily prepared, amateurishly designed, lacks a proper infrastructure, and was issued without a visionary perspective. This regulation risks transforming health tourism from a dynamic sector into a process that exists only on paper.

As the name suggests, health tourism;
• Ministry of Culture and Tourism,
• Turkish Travel Agencies Association (TÜRSAB)
• Ministry of Health,
• Ministry of Family and Social Policies (for senior and disabled tourism),

• Ministry of Trade (for service export management),
• Service Exporters Association (HIB)
A regulation prepared without long-term consultations with institutions such as these, unfortunately, cannot adapt to the realities of the sector.

Group A Travel Agency Requirement

While the Ministry of Trade's definition of service exports under Law No. 5448 mandates Group A travel agencies, the elimination of this requirement with this new regulation and the introduction of new obligations such as complication insurance without coordination and discussion with the incentive processes is a clear indication of a significant inconsistency.

This clearly shows that the lack of consultation and coordination is extreme, and the resulting arrangement is the starting point of a deadlock.

Furthermore, whether the accreditation system to be prepared by TÜSKA will be recognized internationally and accepted by international patient funds and insurance organizations remains a major question mark.

The Logic of the "Income Model"

This approach, which seeks to integrate healthcare facilities into its own system using a specific "revenue model" logic, is detached from the realities of the sector and will increase bureaucratic pressure.

USHAŞ's attempt to centralize health tourism solely to increase its own revenue will deal a severe blow to the strong and independent structure of health tourism within international networks.

Especially in medical aesthetics, the revenue model created through high-priced certificates obtained after a few weeks of courses is being attempted here as well.

In other words, instead of a model for the country to earn foreign currency, the goal was a model for generating revenue for specific institutions.

Travel agencies, health tourism associations, federations, and real field actors are being ignored;
• This is clearly contrary to the Travel Agencies Act enacted in 1972.
• It considers all investments made to date by 1257 brokerage firms null and void.
• And it shows that the assistance companies that have been managing the health of tourists in the field for years are also being excluded from the system.

The regulation was created solely on a "I did it, so it's done" basis, with limited consultations with a few executives from large chain hospitals, completely disregarding the sector as a whole.

Health tourism is too valuable and multi-stakeholder sector to be left solely to the initiative of a small structure within the ministry.

With this regulation:
• Opportunities have been created for illegal brokers who don't even have residence permits,
• Travel agencies and genuine service exporters have been excluded,
• The country's strong international network in health tourism has been weakened.
What should really be done is;
• In coordination with institutions such as the Ministry of Culture and Tourism, the Ministry of Health, the Ministry of Family and Social Policies, the Ministry of Trade, TÜRSAB (Turkish Association of Travel Agencies) and HİB (Turkish Association of Travel Agencies),
• With the active participation of regional health tourism associations, federations, professional organizations, and the academic community,
• Within the framework of a genuine industry consensus,
• The goal is to prepare a regulation that complies with international norms and international competition conditions.

Otherwise, this powerful system, which generates foreign currency for our country in the short term,We have sabotaged the sector with our own hands. We will be.
Cutting down the tree we're sitting on could have dire consequences, like destroying the entire forest together.

Therefore, our call as industry stakeholders is this:

This regulation It should be urgently reviewed and repealed. Instead, a new regulation should be implemented that encompasses the entire sector, is realistic, and will increase our international competitiveness.

To safeguard the future of health tourism in our country, we must take the right steps.