Does a School Psychologist, Speech Therapist or Rehabilitation Specialist Need a Medical License in Ukraine?

Creating a safe and inclusive educational environment is one of the main priorities of modern Ukrainian schools. Educational institutions employ not only teachers, but also professionals in related fields: practical psychologists, speech therapists, special education teachers, physical rehabilitation specialists, and massage therapists.

For the management of an educational institution or private learning center, this raises an important legal question: where is the line between educational or developmental and corrective work and medical practice? Incorrectly classifying the services provided by these professionals at a school can lead to serious consequences during inspections, ranging from fines to allegations of conducting medical practice as a business activity without the required license.

If a school or private educational center engages a psychologist, speech therapist, rehabilitation specialist, or massage therapist, the first step is to assess not the job title, but the substance of the person’s actual work. The nature of the services determines whether the activity remains within the scope of educational or corrective work or already has the characteristics of medical practice.

Where Is the Line Between Non-Medical Services and Medical Practice?

To determine whether a Ministry of Health license is required, it is necessary to identify how the law classifies the services the professional will actually provide.

Under the Law of Ukraine “On Licensing of Types of Economic Activity” and the Fundamentals of Ukrainian Legislation on Health Care, medical practice is a type of business activity in the health care sector carried out by health care institutions or individual entrepreneurs (FOPs) for the purpose of providing medical care and medical services.

For an activity to qualify as medical practice, the law and the Licensing Conditions (Cabinet of Ministers Resolution No. 285) identify several mandatory characteristics:

1. Provider (Who provides the service?). The activity is carried out by professionals with the relevant specialized medical education (confirmed by a diploma from a medical university or college, a specialist physician certificate, or a qualification category certificate).
2. Nature of the actions (What services are provided?). This includes the prevention, diagnosis, and treatment of diseases, injuries, or pathological conditions, as well as medical rehabilitation.
3. Use of medical technologies and protocols. Care is provided in accordance with clinical protocols and standards approved by the Ministry of Health of Ukraine.
4. Classification of occupations and list of positions. The employee’s position is included in the Nomenclature of Medical Specialties or the List of Positions of Professionals/Specialists in the Health Care Sector approved by the Ministry of Health.

For a school, this can be reduced to one practical question: is the professional working within educational or developmental and corrective activities, or are they actually providing medical care or medical rehabilitation?

1. Educational / Developmental and Corrective Activities: Governed by the Law of Ukraine “On Education” and regulations of the Ministry of Education and Science of Ukraine and aimed at teaching, upbringing, socialization, adaptation, or developmental correction of students. No Ministry of Health license is required.
2. Medical Care / Medical Services: Governed by regulations of the Ministry of Health of Ukraine, involve medical intervention or diagnosis, and require a valid medical practice license.

Important! If an educational institution operates a medical office where primary care is provided, preventive examinations are conducted, or physician’s orders are carried out, including with the involvement of an in-house nurse, the activity requires a Ministry of Health medical practice license or engagement of a licensed health care institution under a contract.

But what about related professionals who work with children? The following sections examine the legal status of each of them in detail.

Also useful in this context: Obtaining a Medical License for an Educational Institution: Legal Structuring Models and Ministry of Health Requirements.

Does a School Psychologist or Psychotherapist Need a Ministry of Health License?

Supporting students’ mental health is one of the most active areas in modern schools. However, the overlap between psychological support and psychotherapy often creates confusion about whether a Ministry of Health license is required. To clarify the issue, two roles and two types of activity must be distinguished: a practical psychologist and a physician-psychotherapist / psychological support and medical treatment.

Practical Psychologist (Education Professional)

A practical psychologist at an educational institution works in accordance with the Law of Ukraine “On Education” and the Regulations on Psychological Services in the Education System of Ukraine.

• Education and status: Has a humanities/education background (a degree in specialty 053 “Psychology” or “Pedagogy and Psychology”). The person is classified as an education professional at the institution.
• Role at the school: Psychological and educational assessment of children, support with adaptation, assessment of intellectual and emotional development, bullying prevention, counseling for parents and teachers, and psychological correction sessions.
• Ministry of Health license required: NO. The work of a practical psychologist at a school is not medical practice. It is intended to support the educational process, healthy personal development, and psychological support. Neither the school psychologist nor the institution needs a Ministry of Health license for this work.

Psychotherapist: Medical and Non-Medical Models of Practice

This is where the distinction becomes more nuanced, because the term “psychotherapy” has two interpretations in Ukrainian law and practice.

A. Physician-Psychotherapist (Medical Practice):

• Status: A professional with higher medical education (a physician who has completed specialization in “Psychotherapy” or “Psychiatry”).
• Role: Diagnosis and treatment of mental disorders, neuroses, and borderline conditions. This professional may prescribe pharmacotherapy (medication) and provide psychotherapeutic treatment in accordance with Ministry of Health medical protocols.
• Ministry of Health license required: YES. When a physician-psychotherapist is engaged at a school to treat mental disorders and provide medical care, the work must be performed within the licensed specialty of “Psychotherapy.”

B. Counseling Psychologist / Certified Psychotherapist (Humanities-Based Practice):

• Status: A professional with a basic psychology degree who has also trained in a particular psychotherapy approach, such as Gestalt therapy, CBT, psychoanalysis, etc.
• Role: Working with emotional difficulties, age-related crises, stress, and family problems. The professional does not make medical diagnoses or prescribe medication.
• Ministry of Health license required: NO. General social-psychological or counseling work that does not involve treating clinical pathologies is not considered medical practice.

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Speech Therapists and Special Education Teachers at School

The work of speech therapists and special education teachers (teacher-speech therapists, special education professionals, oligophrenopedagogues, and teachers of students who are deaf or hard of hearing) is fundamental to inclusive education. They help children overcome speech disorders, develop cognitive processes, and adapt to learning.

However, because their work affects a child’s physiological and speech functions, owners of educational institutions often question whether such corrective sessions constitute medical practice.

The legal assessment depends on the services actually provided, the professional’s training, and the rules under which the office operates.

Speech Therapists and Special Education Teachers as Education Professionals

In general secondary schools and inclusive resource centers (IRCs), the work of speech therapists and special education teachers is generally organized as educational activity.

• Legal status: Speech therapists and special education teachers are trained within the field of “Education/Pedagogy” (including specialty 016 “Special Education”).
• Nature of services: The work focuses on correcting and developing speech, forming proper pronunciation, developing phonemic awareness, correcting dysgraphia or dyslexia, and developing fine motor skills and coherent speech.
• Ministry of Health license required: NO. Under the Law of Ukraine “On Education” and the Law of Ukraine “On Complete General Secondary Education”, developmental and corrective work is part of the educational process. It is regulated by acts of the Ministry of Education and Science of Ukraine (MES), not the Ministry of Health.

When Does a Speech Therapist’s Work Fall Within the Health Care Sector?

An important recent legal development should be taken into account: the Ministry of Health of Ukraine included the position of “Speech Therapist” (as well as “Language and Speech Therapist”) in the list of positions for health care professionals who participate in rehabilitation.

• When is this considered medical practice? If a speech therapist or special education teacher works at a health care institution (hospital or rehabilitation center) or in a school medical office and provides medical rehabilitation services (for example, restoring speech after traumatic brain injuries or strokes, or in cases of severe neurological conditions, based on a medical referral from a neurologist or psychiatrist).
• Ministry of Health license required: MANDATORY. This applies if an educational institution opens a medical rehabilitation office and employs a speech therapist as a medical rehabilitation professional within the institution’s medical activities.

Key Takeaway for Schools

If your speech therapist or special education teacher conducts speech correction or cognitive development sessions as part of the school’s educational program or an inclusive classroom, a medical license is not required.

The key is to use the correct job title in the staffing schedule (“teacher-speech therapist,” “special education teacher”) and in service agreements (use “developmental and corrective services” or “educational services,” rather than “medical rehabilitation”).

When Does a Rehabilitation Specialist or Massage Therapist at a School Need a Ministry of Health License?

Physical recovery and bodywork are among the highest-risk areas for an educational institution during inspections. This is where the line between physical fitness/wellness activities and medical rehabilitation becomes especially narrow.

To determine the legal licensing requirements, consider each of these specialties separately.

Physical Therapist, Occupational Therapist, and Physical Rehabilitation Specialist

Following updates to the regulatory framework for rehabilitation, the Law of Ukraine “On Rehabilitation in the Health Care Sector” classifies physical therapists and occupational therapists as health care professionals.

When Is a Ministry of Health License Required?

• If the professional provides medical rehabilitation: the child’s functional condition is assessed and an individual rehabilitation plan is developed after injuries or surgery, or for musculoskeletal disorders (for example, cerebral palsy or severe grade III-IV scoliosis), based on a medical referral from a physician.
• If the position in the staffing schedule of the school or private center is listed as “physical therapist,” “occupational therapist,” or “medical rehabilitation specialist.”

When Is a Ministry of Health License NOT Required?

• If the school provides general physical fitness/wellness or developmental and corrective activities (corrective gymnastics, posture-disorder prevention, adaptive physical education).
• If the professional has an education or sports background (for example, a physical education specialist or therapeutic exercise instructor as part of the teaching staff), and the staffing schedule lists the position as “adaptive physical education instructor” or “physical education teacher (corrective focus).”

More information on the requirements for medical rehabilitation, premises, professionals, and licensing is available in the article “How to Open a Rehabilitation Center: Registration, License, and Ministry of Health Requirements.”

Does a Massage Therapist at a School Need a Ministry of Health License?

The legal status of massage depends entirely on the type of massage and its purpose.

A. Medical (Therapeutic) Massage:

• Nature of the service: Massage prescribed by a physician to treat specific conditions (neurological diseases, injuries, dystrophic changes, etc.) and performed using medical methods.
• Ministry of Health license required: MANDATORY.

Therapeutic massage is classified as a medical rehabilitation and physical therapy service. If a school offers therapeutic or restorative massage for medical conditions, it is considered medical practice.

B. Wellness / Hygienic / Sports Massage:

• Nature of the service: General strengthening massage, massage to relieve muscle tension after sports activities, and preventive massage that does not treat pathological conditions.
• Ministry of Health license required: NO.

Wellness massage falls within household or physical fitness/wellness services. However, the school should have clearly drafted internal documents and properly worded agreements with parents so that inspection authorities do not interpret the massage as a medical intervention.

Detailed criteria for distinguishing these activities are provided in our article on a medical license for a massage therapist.

How to Determine Whether a School Professional Needs a Ministry of Health License: 5 Criteria

To avoid legal mistakes and be prepared for inspections, the management of an educational institution or private learning center should conduct an internal audit using a clear legal framework.

Answer these five key questions to determine the status of the services at your school:

None of these criteria should be assessed in isolation. For example, a professional’s medical education alone does not provide a complete answer without analyzing the position in which the person is employed and what they actually do at the school. Likewise, a formal service name will not avoid licensing requirements if the actual substance of the service constitutes medical practice.

What Should You Do If the Line Between Educational and Medical Activities Is Unclear?

For a particular institution, the answer cannot always be reduced to a simple “license required” or “license not required.” A professional may have medical education but work within an educational program, or a school may call a service developmental and corrective even though its actual substance already has the characteristics of medical rehabilitation. Therefore, the entire operating model must be assessed: the professional’s position, duties, agreements with parents, service descriptions, and how the office operates.

The appropriate solution may differ depending on the results of the review. In one case, it may be enough to revise staffing and contractual documents and keep the activity within an educational or developmental and corrective model. In another, it may be appropriate to establish the school’s own medical office. If the institution plans to provide a broader scope of medical or rehabilitation care, the licensing model and the requirements for premises, staff, and equipment must be determined separately.

The lawyers at Pravova Dopomoga can analyze your operating model and determine which approach fits your institution: whether it is enough to bring the documents into compliance, whether a medical office needs to be established, or whether the activity already requires a medical practice license.

Planning to engage a psychologist, speech therapist, rehabilitation specialist, or massage therapist, or to open a medical office at an educational institution? Call our toll-free number or submit a request on our website—we will help determine the appropriate legal model and structure the professionals’ work in line with the actual services provided.

Learn more about our legal support for establishing a medical office at an educational institution here.