When a Medical Facility Needs a New Accessibility Report When Expanding Its Practice

A physician operating as an individual entrepreneur (FOP) opens another office, a clinic adds a new specialty, or launches a branch at a different address. For a medical business, this is a normal stage of growth, but it also requires the information in its licensing file to be updated correctly.

At this stage, a practical question often arises: can the existing accessibility report for persons with reduced mobility (PRM) be reused, or will another assessment need to be commissioned?

A new report does not have to be obtained automatically every time a practice expands. At the same time, relying solely on the fact that “the document was obtained at some point” is risky. What matters is not merely that a report exists, but which premises it covers, whether those premises have changed, and whether the document reflects the property’s actual condition.

Below, we explain when an existing report can be reused and when expanding a medical practice will require a new assessment.

What Determines Whether a New Accessibility Report Is Required

The obligation to provide barrier-free access for persons with disabilities and other persons with reduced mobility (PRM) to buildings and premises is one of the key requirements under the Licensing Conditions for Medical Practice. Compliance of specific premises is documented by an accessibility report (or technical report) issued by a certified expert.

An accessibility report for persons with reduced mobility is tied primarily to the property and its actual characteristics, not to the medical license itself or a particular medical specialty. Therefore, to determine whether changes in medical practice require a new assessment and another expert visit, three key factors should be checked.

Are the Premises Used for Medical Practice Changing?

If the changes concern the list of medical services (new medical specialties) within offices that have already been assessed and included in the license, the link to the premises’ structural characteristics remains unchanged. In other words, a new report is not required.

The situation is different when a medical business opens a new branch, leases an additional office, occupies another floor, or moves its medical practice to a new address. In that case, you need to determine whether the existing PRM accessibility report covers those premises.

Have There Been Any Alterations or Other Structural Changes?

Even at the same address, the premises may have changed after the assessment. For example, the space may have been reconstructed or remodeled for new equipment or a new specialty, the entrance configuration may have changed, corridors may have been widened, or restrooms relocated. In that situation, the original accessibility report may no longer confirm the actual condition of the premises.

Accordingly, it is necessary to assess not only the address, but also whether the property remains in the same condition in which the expert inspected it during the previous assessment.

Important! Any construction-related changes require new control measurements to verify compliance with the State Building Standards (DBN).

Can an Existing Accessibility Report Be Reused?

The report itself must also be checked: whether the assessed property can be identified unambiguously, whether the expert held the required qualifications, and whether the document matches the actual condition of the premises. We discuss the detailed review criteria below, but the key point is that this review determines whether the existing accessibility report can be reused without paying for another assessment or whether a new document is required.

More on accessibility requirements for healthcare facilities, premises assessments, and the contents of the accessibility document: Accessibility of Healthcare Facilities and Pharmacies for Persons with Disabilities: Legal Requirements

New Medical Practice Address: Can the Existing Report Be Reused?

If a clinic or an individual entrepreneur (FOP) opens a new branch or completely changes the physical location of its operations, the existing PRM accessibility report cannot be used for the new address. In that case, the property itself has changed, and the accessibility of the new property must be confirmed.

Why Does a New Address Always Require a New Report?

1. Individual architectural and structural characteristics. Every building and set of premises has a unique configuration: threshold heights, door opening widths, ramp slopes, the presence or absence of lifts, specially adapted restrooms, and so on.
   
   Even if your new premises are in the same building but on another floor or in an adjacent unit, their barrier-free accessibility must be assessed separately.
2. Requirements for identifying the property in the Unified State Electronic System in the Construction Sector (ЄДЕССБ). Under current rules, every accessibility report is registered in ЄДЕССБ. When making the entry, the expert specifies the property address, its cadastral number (if any), the registration number of the real estate asset, and the specific premises or areas covered.
3. Assessment of routes of movement and the entrance area. Accessibility of a healthcare facility begins on the surrounding grounds—with designated parking spaces for persons with disabilities, a barrier-free route to the building, and an appropriately designed entrance area.
   
   If the address changes, all of these elements are new and must undergo mandatory technical assessment.

Therefore, when opening a medical practice at a genuinely new address or in a property that was not covered by the previous assessment, a document for the new premises must be obtained.

This should be taken into account before filing changes with the Ministry of Health. If the need for a new assessment is identified only during document preparation, the launch of the new location will have to be postponed until the documentation is brought into compliance.

Is a New Report Required When Expanding the Premises at the Same Address?

A more complex situation arises when the address formally remains the same, but the clinic or private practitioner leases another office, part of a floor, or an adjacent unit. The fact that the additional space is in the same building does not mean that the existing report is sufficient. The key is to determine what exactly the expert inspected previously.

If the report covered only a specific office or a defined part of the premises, and the clinic is now adding space that was not included in the document, accessibility of that additional space must be assessed separately.

A new assessment will also be required if the additional premises have a separate entrance or if reconstruction or remodeling was carried out to connect them.

The situation is different if, during the first assessment, the expert inspected the entire unit, floor, or all premises, but the clinic initially used only part of them. For example, the report may describe five offices even though medical practice was initially conducted in only two. If the clinic later begins using another office that was already assessed and the premises have not changed since the assessment, a separate repeat assessment may not be necessary.

The decision therefore depends not on the words “same address,” but on how the additional space relates to the space actually covered by the existing report.

New Specialty at the Same Address: Is a New Accessibility Report Required?

What matters here is not the mere addition of a specialty, but whether the premises change because of it. If a different office is used for the new area of practice, the logic from the previous section applies: determine whether that space is covered by the existing document. Special attention is required where the nature of the new specialty requires an existing office to be reconfigured.

A less obvious risk arises when the new specialty physically changes the premises. Some specialties require specialized equipment or particular zoning—for example, X-ray rooms, sterilization rooms, or operating blocks. This may require moving walls or door openings, narrowing passageways, or installing equipment that changes the route of movement through the premises.

If such reconfiguration changes parameters that affect accessibility, the previous report may no longer describe the property’s actual condition. The altered premises must then be reassessed for compliance with accessibility requirements.

For example, if a clinic adds a cardiologist to an existing office without remodeling, a new report is not required solely because a new specialty was added. But if the premises are rebuilt for an X-ray room or equipment is installed in a way that changes the width of a passage or the free space available for movement, the continued validity of the previous report must be reviewed.

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How to Check Whether Your Existing PRM Accessibility Report Is Suitable

Even if the address and configuration of the premises have not changed, using a previously issued PRM accessibility report when amending a license (adding specialties or addresses) requires a legal review. To make sure your existing report is suitable for submission to the Ministry of Health, audit the document against four core criteria.

Registration in the Unified State Electronic System in the Construction Sector (ЄДЕССБ)

This is a key indicator of the document’s validity. Since 2021, all accessibility reports and technical reports for PRM accessibility must be registered in ЄДЕССБ and assigned a unique registration number (with a QR code).

How to check: Find the document in the public ЄДЕССБ register using its number or the expert or business entity details.

Validity of the Expert’s Qualification Certificate

An accessibility report may be issued only by a certified expert in the technical inspection of buildings and structures who holds the appropriate qualification certificate.

Risk: If, when the document was issued, the expert’s certificate had been suspended or revoked, or the expert had not completed the required periodic professional development (once every 5 years), the report is considered invalid.

Compliance with Current Building Standards (DBN V.2.2-40:2018)

The accessibility assessment must be performed under the current State Building Standards—DBN V.2.2-40:2018 “Inclusivity of Buildings and Structures.”

How to check: Make sure the document directly refers to calculations and requirements under this DBN, rather than the outdated DBN V.2.2-17:2006.

Completeness of the Property and Premises Description

The document should contain comprehensive information about the assessed property:

• the address matching the data in the State Register of Rights to Immovable Property;
• the specific premises covered (office numbers, floors, total and usable area);
• a detailed description of the entrance area, corridors, restrooms, and routes of movement.

Lawyer’s tip: If your report was issued several years ago and meets all of the requirements above, but even minor cosmetic works involving additional space have been carried out since then, it is safer to have the document legally reviewed before submitting the information to the Ministry of Health. This will save time and help avoid delays in expanding the business.

What Must Be Submitted to the Ministry of Health When Expanding a Medical Practice?

Any change in medical operations—opening a new address, adding medical specialties, or changing working hours—requires the licensing information to be updated. Under the Licensing Conditions, a business entity must notify the Ministry of Health of Ukraine of all changes to the information stated in the application and the documents submitted with it when the license was obtained.

The notification procedure requires compliance with the following statutory requirements:

• The Notice of Changes must be submitted to the Ministry of Health of Ukraine within one month from the date the change occurs.
• The licensing authority must receive the prescribed Notice of Changes form together with updated Information on the state of the material and technical resources and the availability of personnel, including their educational and qualification levels.
• If the addresses or premises are expanded, the updated information must include the details of the PRM accessibility report for the premises (or a new report registered in ЄДЕССБ).
• Documents may be submitted in person, by mail with an inventory of enclosures, or electronically through available electronic services.

Failure to notify the authority of changes, or late notification, violates the Licensing Conditions and may result in an unscheduled inspection or suspension of the license.

We explain the Ministry of Health notification procedure in detail in a separate article: Notifying the Ministry of Health of Changes in Medical Practice: Instructions.

How to Avoid Unnecessary Costs and Delays When Expanding a Medical Practice

When expanding a medical practice, the goal is not to order the maximum number of documents “just in case,” but to determine exactly what your situation requires.

If the existing report already covers the required premises, a repeat assessment may be an unnecessary expense. If the business begins operating in additional space or has changed the property’s configuration, however, attempting to use the old document may create problems when the amendments are filed.

Before filing, compare three things: the clinic’s new operating model, the actual premises in which it will be implemented, and the documents already contained in the licensing file.

Our medical law lawyers can review the existing report and documents for the premises, determine whether a new assessment is required, and prepare amendments to the licensing file to reflect a new address, additional space, or specialties.

As a result, you receive not merely a set of documents, but a clear roadmap for expanding the practice: what can be reused, what must be supplemented, and what steps must be completed before operating under the new model. This avoids spending money on procedures your situation does not require and allows the amendment process to be handled by the team without you having to navigate every licensing-file requirement yourself.

If you are planning a new address, office, or specialty and want to know in advance whether your existing accessibility report is sufficient, contact us. We will review the documents and determine which filing approach is appropriate for your expansion.

Learn more about legal support for amendments and medical license expansion here.