Opening a second clinic: registration and rules Can a doctor run two clinics, what each premises needs, and how to keep the records apart.

Yes, a doctor can run two clinics in India. We read the 2002 conduct regulations for this post and found no rule that limits the number of places a doctor may practise. What the law does attach to each place is registration: the clinical establishment registration, bio-medical waste authorisation and any drug licence are issued for premises, so a second clinic needs its own. The doctor's council registration carries over; nearly everything else is done again for the new address.

What carries over from the first clinic, and what does not?

Does a branch need its own clinical establishment registration?

In states that follow the central Act, yes. Section 2(c) defines a clinical establishment as a hospital, nursing home, dispensary, clinic or other institution "by whatever name called", including one owned or managed by a single doctor. Section 11 says: "No person shall run a clinical establishment unless it has been duly registered in accordance with the provisions of this Act." Section 12 makes registration conditional on the minimum standards of facilities and services, the minimum personnel, and records and reporting, all of which are tested against a specific premises. Section 18 says the certificate is kept affixed in a conspicuous place in the establishment, visible to everyone visiting it. One certificate cannot hang in two clinics.

Apply under section 14 to the registering authority for the district where the new clinic is; if the branch is in a different district from the first, that is a different authority. Section 14(4) asks a new establishment to apply for permanent registration within six months of being set up. States with their own Acts have their own forms and timelines; our Clinical Establishments Act states list shows which law applies where.

Drug licence and bio-medical waste at the second clinic

Rule 62 of the Drugs and Cosmetics Rules, 1945: "If drugs are sold or stocked for sale at more than one place, separate application shall be made, and a separate licence shall be issued, in respect of each such place." If the first clinic has a pharmacy counter on a Form 20 or 21 licence, the branch needs its own licence, its own premises inspection and its own registered pharmacist. A doctor who only supplies medicines to their own patients under Schedule K item 5 needs no licence, but should keep the purchase records and supply register for each clinic separately so stock can be traced to the place it was given. See Schedule K dispensing.

Rule 10 of the Bio-Medical Waste Management Rules, 2016 requires every occupier handling bio-medical waste, "irrespective of the quantity", to apply in Form II to the State Pollution Control Board. Apply for the new address, and sign up with the common waste treatment facility that serves that area.

Can one doctor practise at two clinics at the same time?

The 2002 regulations do not set a limit, and we did not find a provision on practising at two places. Three rules shape how it is done:

• Regulation 7.13: it is improper "to affix a sign-board on a chemist's shop or in places where he does not reside or work". Your name goes on the board of a clinic only if you work there.
• Regulation 1.4.1: every physician displays their registration number in their clinic and on all prescriptions, certificates and money receipts. Do it at both places.
• The Ministry's standard for consultation clinics asks each clinic to display the names of its doctors with registration numbers, their fees and the clinic's timings (CEA/Clinic-008, para 3.5). Each branch's board should show who is there and when, so a patient is not told "doctor comes on Tuesdays" at the door.

If the doctor will be at one clinic while the other stays open, plan who sees patients at the other. Para 5.1 of the standard says the clinic's doctors shall be registered with the medical council, and para 5.2 says services must be in consonance with each professional's qualification, training and registration, so the front desk at the second clinic cannot run consultations in the doctor's absence.

Should the two clinics keep separate records?

Yes. Each registered establishment answers for its own records: para 9.1 of the standard says every clinical establishment maintains medical records of patients treated by it and reports statistics to the district authorities. Keep a separate patient register, certificate register and bill series at each clinic. A patient who visits both should be able to ask either clinic for their records and get them within 72 hours (2002 regulation 1.3.2), so decide early which clinic holds which visit, and who at each place handles a request.

• Separate bill number series per clinic, so the day book of each tallies on its own.
• Separate cash drawers and UPI QR codes, or at least a clear daily split by clinic.
• One person at each clinic responsible for the patient register, certificate register and record requests.
• The clinic name and address of the branch on its prescriptions and receipts, not the first clinic's.