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.
By mubin1156
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