In-Person and Online Psychiatric Care: How to Structure a Private Practice

A psychiatrist approached us while preparing to launch her own medical practice. She planned to see adult patients independently, both in her office and online, diagnose conditions, prescribe treatment, and issue electronic prescriptions. She needed documents for working with patients and clear guidance on maintaining her continuing professional development (CPD) portfolio.

Initially, her request was broad: a complete list of logs, orders, policies, standard operating procedures, consent forms, and medical records. After reviewing her practice model, we did not impose the documentation package of a large clinic on a solo practitioner. Instead, we identified the essential minimum, prepared five interconnected materials, and separately answered the questions the client raised after reviewing them.

This case shows why the legal preparation of a private medical office begins not with the number of templates, but with the physician's actual practice model.

The Client's Request: An Individual Practice Model for a Psychiatrist

The client was still preparing to begin working specifically as a psychiatrist. She had already submitted her application for a medical practice license and wanted to put her documentation in order before her first patient appointment. During our initial consultation, we established her intended practice model:

• patients — adults only;
• appointment formats — in-person office visits and remote consultations;
• services — psychiatric examinations, consultations, diagnosis, prescribing treatment, and adjusting treatment;
• electronic prescriptions, including prescriptions for psychotropic medications;
• solo practice with no employees;
• no injections, specimen collection, or other medical procedures;
• no storage of medications at the office;
• private-pay services without a contract with the National Health Service of Ukraine (NHSU);
• appointments booked through an online service, by telephone, and through messaging apps.

These answers immediately narrowed the scope of work. The psychiatrist did not need personnel records, job descriptions, procedures for medical interventions, or a documentation package intended for a multidisciplinary facility. However, risks specific to psychiatric care remained: special informed-consent forms, confidentiality of mental health data, remote consultations, electronic prescriptions, and boundaries for communicating with patients.

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Why We Rejected a “Complete Package” and Standard Medical Documentation Templates

Initially, it would have been possible to compile dozens of documents. For the client, this would have meant substantial unnecessary expense and a folder containing materials that did not correspond to her actual work.

The opposite extreme would have been to download a few generic consent forms from the internet. Such a collection does not address appointment cancellations, refunds, remote consultations, responses to a crisis, electronic prescriptions, the disclosure of medical information, or the use of digital channels.

We therefore divided the documents into three groups:

• official Ministry of Health forms, which must be used in their current versions rather than rewritten for individual purposes;
• customized documents that must reflect how consultations are actually conducted;
• materials that may be needed later if employees, new services, a website, an NHSU contract, medical procedures, or other processes are added.

After making this distinction, we agreed not on “complete readiness for any inspection” but on a specific outcome: establish the rules governing the patient relationship, provide the correct list of standard medical forms, and explain the CPD requirements.

Developing Documents for Online and In-Person Medical Services: What We Prepared for a Psychiatrist Operating as a Sole Proprietor

Roadmap for Approving and Implementing the Documents

The text of a document alone does not tell the recipient what to do with it. We therefore prepared separate instructions covering which documents the psychiatrist should approve by her own order, what she should communicate to patients, which records of patients' acknowledgment to retain, how to number document versions, and what to review when services change.

The roadmap also distinguished the documents from the prerequisites for starting work: holding a medical practice license, registering in Ukraine's electronic health care system (ESOZ) through a medical information system, having a qualified electronic signature, and ensuring that the equipment actually used matches the information submitted for licensing.

This is a fundamental distinction. A set of patient-facing rules does not replace a license and does not, by itself, establish that the medical practice is ready to launch.

Terms and Conditions for Paid Psychiatric Services

The main customized document was the terms and conditions for in-person and remote consultations. These covered:

• the list of services and their scope;
• appointment booking, confirmation, lateness, rescheduling, and cancellation;
• payment, advance payment, and refunds;
• patient identification during remote consultations;
• circumstances in which an online consultation must be stopped and in-person or emergency care recommended;
• the procedure for prescribing treatment and issuing electronic prescriptions;
• rules for communication between appointments;
• confidentiality and disclosure of medical information;
• the rights and obligations of the physician and the patient;
• the absence of any guarantee of a predetermined treatment outcome.

We specifically stated that acceptance of the organizational and financial terms does not replace informed consent to a psychiatric examination or outpatient psychiatric care. These are different documents serving different purposes.

Notice on the Processing of Personal and Medical Data

For a psychiatric practice, a generic statement such as “I consent to the processing of personal data” is not sufficient. The patient must understand what data the physician collects, why the data are needed, which services process them, to whom they may be disclosed, and how the patient can exercise their rights.

We tailored the notice to the client's actual channels: the online booking system, telephone, messaging apps, email, medical information system, ESOZ, and bank payments. We also explained that an ordinary chat is not a place for maintaining medical records and that clinically significant information must be entered into the medical record.

Important! The Law of Ukraine “On Personal Data Protection” and official guidance issued by the Ukrainian Parliament Commissioner for Human Rights classify information about a person's health as sensitive data. That is why this area requires not only appropriate wording in the patient notice, but also actual procedures for access, storage, and incident response.

List of Standard Medical Forms With Official Sources

We did not sell the client forms that had already been approved by the government. Instead, we provided a list of current forms, explained when each applies, and included links to official sources. For her chosen practice model, the key items included:

• Form No. 003-7/o — informed consent to a psychiatric examination;
• Form No. 003-8/o — informed consent to outpatient psychiatric care;
• medical records in ESOZ through the selected medical information system;
• forms and reports whose reporting requirements cover private psychiatric practices.

Important! Forms No. 003-7/o and No. 003-8/o were approved by Ministry of Health Order No. 970 dated September 15, 2016. They should not be arbitrarily shortened or replaced by the terms and conditions for paid services.

Personal CPD Guidance Note

The client was transitioning from employment to her own practice and wanted to understand who reviews the portfolio, where it must be submitted, and how CPD points should be documented.

The guidance distinguished three situations: employment, operating exclusively as a sole proprietor (FOP), and a transition year in which both statuses applied. It also described how to verify the event provider, certificate number, number of CPD points, and supporting documentation.

As of the date of our work, Ministry of Health Order No. 650 dated April 16, 2025 provided for the resumption of professional attestation six months after martial law ends or is lifted. At the same time, the obligation to maintain an individual educational portfolio and record CPD points had not been suspended.

Also of interest: How to Conclude an Agreement With the NHSU: A Step-by-Step Guide for Healthcare Facilities and Sole Proprietors 

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The Psychiatrist’s Practical Questions

After receiving the documents, the client—a psychiatrist operating as a sole proprietor—carefully reviewed the package and raised practical questions.

1. Does a physician who works exclusively as a sole proprietor need to submit their portfolio anywhere every year before attestation resumes?
2. Who will receive the documents once attestation resumes?
3. Is the notification to the Commissioner concerning the processing of sensitive data still applicable?
4. Must a private psychiatrist submit Forms No. 10 and No. 17 without an NHSU contract or employees?
5. Is it mandatory to create five to seven separate data protection policies?

This stage became part of the deliverable, rather than a sign that the documents were inadequate. A well-prepared package must withstand the user's questions and explain how the law operates within that person's particular practice model.

We separately reviewed each of these issues and provided written explanations.

How We Clarified the Unresolved Issues

Regarding CPD, we explained that if a physician works exclusively as a sole proprietor (FOP) and has no employment relationship, the current procedure does not establish an employer to whom the physician submits a portfolio each year. The portfolio must be maintained, certified by the physician, and retained together with the certificates. The submission procedure for attestation should be checked against the rules in effect when attestation resumes.

Regarding personal data, we confirmed that the notification concerning processing that poses a particular risk and the notification concerning the responsible person remain applicable. For a sole proprietor with no employees, the entrepreneur may personally perform the function of organizing data protection, but the actual processes must still be regulated.

Regarding internal policies, we did not insist on artificially multiplying documents. For a solo practice, the main rules may be consolidated into one operational procedure: access, storage, transfer, backup, and deletion of data, incident response, and records of processing operations.

Regarding statistical reporting, we explained that the absence of an NHSU contract is not a blanket exemption. Form No. 10 covers sole proprietors who hold a license and provide psychiatric care, while the current Form No. 17 covers sole proprietors with a medical practice license. This follows from Ministry of Health Order No. 1504 and the current version of Form No. 17. The specific deadlines and submission method must be checked for the relevant reporting year.

What the Client Received

The client received not an abstract list of “everything that might be found in a medical office,” but a system of five materials.

1. An implementation roadmap.
2. Terms and conditions for paid psychiatric services.
3. A notice on the processing of personal and medical data.
4. A list of current official forms.
5. A personal CPD guidance note.

As a result, the client received not just the documents themselves but a clear procedure for implementing them: what to approve by her own order, what to explain to the patient, which evidence to retain, how to use the official forms, and how to manage CPD. This allowed her to avoid spending money on dozens of generic templates and focus on documents matching her actual model of in-person and remote consultations. After receiving the package, she asked follow-up questions and received written answers with links to current sources.

What This Case Means for Other Physicians Operating as Sole Proprietors

For a physician operating as a sole proprietor, the documentation package must reflect the practice's actual model and change along with it. Before preparing or updating the documents, five matters should be checked:

• exactly which medical services the physician provides;
• who the patients are and who has access to their data;
• where appointments take place — in the office, online, or during visits to patients;
• which official forms, ESOZ records, and reports apply;
• which processes actually exist and which have merely been copied from someone else's document package.

For a single physician, a compact set of coordinated documents may be optimal. Once an administrator is hired, a website is launched, children are treated, medical procedures are performed, medications are stored, or an NHSU contract is concluded, the package must be reviewed.

How We Can Help With Medical Practice Documentation

We conduct a legal review of a physician's or healthcare facility's practice model, distinguish mandatory official forms from customized documents, and prepare a package tailored to the actual processes. As part of our legal support for healthcare facilities, we can:

• review the consultation model, digital channels, and document workflows;
• identify the essential minimum of documents;
• prepare terms and conditions for paid medical services;
• establish rules for remote consultations and patient communications;
• draft documents relating to personal and medical data;
• provide a list of current forms and instructions for their use;
• explain CPD and statistical reporting requirements;
• prepare an implementation roadmap.

If you are opening a private practice or already operating one but are unsure whether your documents reflect your actual processes, contact us. We will first identify your practice model and risks, then propose a scope of work that is genuinely worth paying for.