Updated as at 25 Nov 2021

Emergency Ambulance Service (EAS) Regulations

Medical Transport Service (MTS) Regulations
Frequently Asked Questions

Table of Contents
Transition from the Voluntary Accreditation Scheme (VAS) to Healthcare
Services Act (HCSA) Regulations ..................................................................... 3
[Updated as at 10 Aug 2021] When will the EAS and MTS Regulations under HCSA
come into force? ...................................................................................................... 3
[Updated as at 10 Aug 2021] How will PAOs who are currently accredited under the
VAS transition to HCSA? ......................................................................................... 3
[Updated as at 19 Oct 2021] What should PAOs who are not accredited under the
VAS do if they wish to continue operating under HCSA? ......................................... 3
[Updated as at 10 Aug 2021] Will PAOs who are accredited under the VAS be able
to update the vehicle information prior to HCSA coming into force? ........................ 3
What should PAOs do if they do not intend to continue providing ambulance
services once HCSA comes into force?................................................................... 4
What are the costs involved for the transition of PAOs accredited under the VAS to
HCSA? .................................................................................................................... 4
[Updated as at 10 Aug 2021] What are the various types of service licences related
to private ambulance services under HCSA? .......................................................... 4
Will PAOs be able to cope with the new requirements? Will regulations be too
onerous for smaller players to invest and upgrade their fleet of ambulances to serve
as emergency ambulances? .................................................................................... 5
Requirements in the HCSA EAS and MTS Regulations ................................... 5
What are the key areas that will be regulated? ........................................................ 5
Are there any differing / additional requirements from the current MOH Standards
for EAS/MTS (2017) that will be under the new regulations? ................................... 5
Is there a limit to the number of ambulances allowed per licence? .......................... 5
Can an EAS licensee also provide MTS? Does a separate licence need to be
applied? .................................................................................................................. 6
Do the EAS and MTS Regulations only cover land vehicles, and not other modes of
conveyances (e.g. air)? ........................................................................................... 6
[Updated as at 10 Aug 2021] Can I appoint the same person to be the Principal
Officer (PO) and Clinical Governance Officer (CGO) (previously referred to as the
“Clinical Director” (CD))? ......................................................................................... 7
What is the requirement for the CGO to demonstrate good standing? ..................... 7
[Updated as at 10 Aug 2021] For EAS, can specialists of specialties other than
Emergency Medicine be appointed as the EAS CGO in my company? ................... 7

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For EAS, in the event where there is no person with relevant experience in
disciplines that manage acute and critical patients to be appointed as CGO in my
company, what should I do? .................................................................................... 7
What if I am unable to appoint a Key Appointment Holder that is able to meet the
requirements stipulated in the Code of Practice?..................................................... 8
Can the same ambulance service crew be used to account for the staffing number
for more than one ambulance? ................................................................................ 8
Can in-training personnel (i.e. pending certification/qualification) be counted
towards the minimum requirement for ambulance service crew? ............................. 8
What are the technical requirements that each ambulance vehicle must meet? ...... 8
Is there any vehicular requirement for ambulances under the new regulations? ...... 8
For PAOs who are already currently on board the VAS, would they still need to be
re-inspected prior to the implementation of HCSA? ................................................. 9
[Updated as at 10 Aug 2021] In the event that an MTS patient deteriorates into an
emergency condition, what should the MTS provider do?........................................ 9
[Updated as at 10 Aug 2021] How should the licensee determine which hospital to
send patients to? ..................................................................................................... 9
[Updated as at 19 Oct 2021] What does a proper handover of a patient entails? .. 10
[Updated as at 10 Aug 2021] Does HCSA regulate the pricing of private ambulance
services? ............................................................................................................... 10
In the event of an emergency which involves a first-time patient, how are we able to
convey the common charges before accepting the patient and prior to actual
conveyance? ......................................................................................................... 10
[Updated as at 19 Oct 2021] In the event of a disagreement by the patient or next-
of-kin to the higher or additional charges arising from the assessment of the
patient’s condition on arrival and prior to conveyance, what should the licensee do?
.......................................................................................................................... 11
[Updated as at 25 Nov 2021] How should I go about obtaining signed
acknowledgement on the charges that are applicable to the patient in the event of
an emergency? ..................................................................................................... 11
What aspects of the EAS and MTS will be inspected under HCSA? ...................... 11
When and how will inspections/audits be conducted on private ambulance
services? ............................................................................................................... 12
[Updated as at 10 Aug 2021] What are the disciplinary actions that can be taken on
accredited / licensed PAOs for non-compliance?................................................... 12
What are the disciplinary actions that can be taken for unlicensed PAOs operating
under HCSA? ........................................................................................................ 12
What should I do if I wish to import an EAS/MTS vehicle for use in Singapore? .... 12
Will EAS and MTS vehicles have free parking? ..................................................... 13
[Updated as at 10 Aug 2021] Are PAOs allowed to loan licensed EAS/MTS vehicles
to another licensed PAO?...................................................................................... 13

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Transition from the Voluntary Accreditation Scheme (VAS) to

Healthcare Services Act (HCSA) Regulations

[Updated as at 10 Aug 2021] When will the EAS and MTS Regulations under
HCSA come into force?

• The EAS and MTS Regulations under HCSA will come into effect on 3 Jan 2022.
Private ambulance operators (PAOs) who intend to provide private ambulance
services in the form of EAS and/or MTS will be licensed under HCSA.

[Updated as at 10 Aug 2021] How will PAOs who are currently accredited under
the VAS transition to HCSA?

• Currently, PAOs assessed to have met MOH Standards for EAS and MTS (2017) for
ambulance services are accredited under the VAS. Accredited PAOs would have
attained the Letter of Accreditation (LOA) and the Certificate of Compliance (COC)
for each vehicle. Accredited PAOs will have their LOAs converted to a service licence
under HCSA if they were assessed to still be compliant with the MOH Standards for
EAS and MTS (2017) at the point of porting over to HCSA.

[Updated as at 19 Oct 2021] What should PAOs who are not accredited under
the VAS do if they wish to continue operating under HCSA?

• From Oct 2021: PAOs who are not on VAS and have earlier expressed interest to
apply for a new EAS/MTS HCSA licence by 30 Sep 2021 will be contacted and invited
to apply for the EAS/MTS HCSA licence under the new electronic licensing system,
HALP, from Oct 2021 onwards. PAOs will be required to pay the applicable licensing
fees under HCSA.

[Updated as at 10 Aug 2021] Will PAOs who are accredited under the VAS be
able to update the vehicle information prior to HCSA coming into force?

• From Oct 2021: PAOs accredited under the VAS who wish to update existing details
(e.g. company name, information on key personnel) and vehicle information (i.e. add
or remove vehicles) may so during the data verification stage from Oct 2021 onwards.
Addition of vehicles will similarly be subjected to inspection before the vehicle details
are transferred to the service licence under HCSA. PAOs accredited under the VAS
will be contacted and invited to perform the data verification under the new electronic
licensing system, HALP, from Oct 2021 onwards.

• From 3 Jan 2022: Once the service regulation for EAS/MTS under HCSA comes into
force from 3 Jan 2022 onwards, any changes to vehicle information (i.e. addition or
removal of vehicles) will be subjected to the necessary inspections and applicable
licence fees under HCSA. More details on licensing fees under HCSA will be
separately released in 2H 2021.

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What should PAOs do if they do not intend to continue providing ambulance

services once HCSA comes into force?

• PAOs who do not intend to provide ambulance services under HCSA must either
convert their existing tax-exempt vehicles out of the ambulance scheme into other
categories of normal tax-payable vehicles or deregister their vehicles through the
Land Transport Authority (LTA) before the EAS and MTS regulations under the HCSA
come into force. For vehicle scheme conversion, there will be a need to pay for a
Certificate of Entitlement (COE) in the appropriate vehicle category and the respective
vehicular fees and taxes (e.g. Additional Registration Fee (ARF), Road Tax, Excise
Duties). PAOs may also deregister their vehicles by: (a) disposing of them at any
LTA-authorised scrapyard; or (b) exporting the vehicles. Vehicle scheme conversions
and/or valid proof of disposal must be submitted to LTA.

What are the costs involved for the transition of PAOs accredited under the
VAS to HCSA?

• PAOs will only have to pay an administrative fee of $100 for registration during the
VAS period to obtain the LOA and COC for each vehicle. The LOA will be converted
to a service licence once HCSA comes into force.

• PAOs who are not on-board VAS prior to HCSA coming into force will have to pay the
licensing fees during the application under HCSA. More details on licensing fees
under HCSA will be separately released in 2H 2021.

• PAOs who are not on-board VAS will also have to incur downtime and opportunity
costs in terms of the time taken from inspection of their vehicles to the approval and
issuance of the service licence before being allowed to operate after 3 Jan 2022.

[Updated as at 10 Aug 2021] What are the various types of service licences
related to private ambulance services under HCSA?

• PAOs who intend to provide MTS conveyances will be required to hold a valid MTS
HCSA service licence. Likewise, PAOs who intend to provide EAS conveyances will
be required to hold a valid EAS HCSA service licence.

• PAOs with a mixture of EAS-equipped and MTS-equipped vehicles providing the

respective types of conveyances can either hold two separate service licences or an
EAS-MTS bundled service licence (refer to question 9 for more details on the fees for
different types of service licences under HCSA).

• PAOs with EAS-equipped ambulances may also choose to use the ambulances to
provide MTS and ferry non-emergency patients, by virtue of the higher standards for
EAS ambulances. However, the relevant requirements for an EAS (i.e. crew
member requirements, equipment etc.) would still apply even if EAS-equipped
ambulances are used to ferry non-emergency patients.

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Will PAOs be able to cope with the new requirements? Will regulations be too
onerous for smaller players to invest and upgrade their fleet of ambulances to
serve as emergency ambulances?

• We have been regularly engaging PAOs on the new regulatory framework since 2017
to ensure that the industry is kept up to date and informed of the requirements. MOH
has also worked with various agencies, such as the Alice Lee Institute of Advanced
Nursing, Institute of Technical Education and Nanyang Polytechnic, to ensure there
are training programmes to upgrade the skills of existing ambulance personnel and
ensure they have sufficient time to meet the crew requirements under the new
standards.

• Since 1 January 2018, MOH has also been actively encouraging the providers to
voluntarily accredit themselves to the new standards under the VAS, so as to raise
their service standards earlier and transition into the licensing framework under the
HCSA. The Paramedic Transition Scheme (PTS) was also rolled out since January
2019 to allow existing ambulance personnel who are not holding approved paramedic
or Emergency Medicine Technicians (EMT) qualifications a one-off opportunity to
obtain approval to practice as paramedics, thereby allowing PAOs to meet the
personnel qualification requirements under VAS and the EAS and MTS Regulations
under HCSA.

Requirements in the HCSA EAS and MTS Regulations

Part 1 General Licensing

What are the key areas that will be regulated?

• The EAS and MTS Regulations under HCSA will stipulate requirements for
governance, quality assurance, ambulance crew personnel, equipment, medical
management, medication supply, infection control and fee transparency.

Are there any differing / additional requirements from the current MOH
Standards for EAS/MTS (2017) that will be under the new regulations?

• Under HCSA, additional requirements for licensees of EAS/ MTS services include
enhanced governance structures, requirements for proper medication supply and
storage, conveyance requirements for Emergency and non-Emergency patients, and
fee transparency.

Is there a limit to the number of ambulances allowed per licence?

• There is no limit to the number of ambulances allowed per licence.

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Can an EAS licensee also provide MTS? Does a separate licence need to be
applied?

• EAS licensees with EAS-equipped ambulances may choose to use the ambulances
to provide MTS and ferry non-emergency patients without having to hold a separate
MTS service licence. However, the relevant requirements for an EAS (i.e. crew
member requirements, equipment etc.) would still apply even if EAS-equipped
ambulances are used to ferry non-emergency patients. In addition, the siren
and beacon lights in the EAS vehicles are only to be used when transporting an
Emergency Patient.

• PAOs will need to hold separate EAS and MTS service licences if the fleet of
ambulances contains both EAS-equipped and MTS-equipped vehicles.

Do the EAS and MTS Regulations only cover land vehicles, and not other modes
of conveyances (e.g. air)?

• The EAS and MTS Regulations of HCSA are focused on ground conveyances
operating as Emergency Ambulances or Medical Transport, and do not cover other
modes of conveyances.

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Part 2 Organisation, Management and Governance of Licensees

[Updated as at 10 Aug 2021] Can I appoint the same person to be the Principal
Officer (PO) and Clinical Governance Officer (CGO) (previously referred to as
the “Clinical Director” (CD))?

• The same person may be appointed as the PO and CGO as long as the person fulfils
the requirements of the PO and CGO and is able to take on the associated roles and
responsibilities.
• While the CD is now renamed as the CGO to align with the terminology used under
HCSA in reference to the person responsible for providing such clinical/technical
oversight, the nature of this role remains the same.

What is the requirement for the CGO to demonstrate good standing?

• This means that the doctor or nurse must not have been subject to any disciplinary
actions by a Disciplinary Tribunal of the Singapore Medical Council or the Singapore
Nursing Board (whichever is applicable) for the preceding three years before
appointment as a CGO.

• This requirement is based on our concern with appointing doctors and nurses found
guilty of more serious offences that suggests a defect in character or a lack of
professionalism, and/or poor competency which may impede their ability to manage
critical clinical incidents or otherwise predispose them to acts that can compromise
patient safety.

[Updated as at 10 Aug 2021] For EAS, can specialists of specialties other than
Emergency Medicine be appointed as the EAS CGO in my company?

• Only Emergency Medicine, Intensive Care, Anaesthesia and General Surgery

Specialists accredited by the Specialist Accreditation Board and registered by the
Singapore Medical Council may be appointed as an EAS CGO without further review,
subject to their meeting other requirements.
• Other registered specialists from specialties with significant training and practice in
acute and/or life-saving interventions will have their applications reviewed by an
MOH-appointed panel.

For EAS, in the event where there is no person with relevant experience in
disciplines that manage acute and critical patients to be appointed as CGO in
my company, what should I do?

• The provision of EAS services should not continue until a CGO is appointed. The list
of approved CGO can be found at: https://www.moh.gov.sg/licensing-and-
regulation/regulations-guidelines-and-circulars/details/list-of-approved-clinical-
directors-for-private-ambulance-operators.
• To seek assistance on CGO-related matters, PAOs can also email to the Unit for Pre-
Hospital Emergency Care (UPEC) at: [email protected].

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What if I am unable to appoint a Key Appointment Holder that is able to meet

the requirements stipulated in the Code of Practice?

• To allow greater flexibility for businesses to meet these clinical

qualification/governance requirements, the CGO can fulfil the requirements and the
KAH will be exempted from the clinical qualification requirement. Please refer to the
FAQs for the Code of Practice for further information.

Part 3 Licensee Personnel

Can the same ambulance service crew be used to account for the staffing
number for more than one ambulance?

• The number and qualifications of the ambulance crew must commensurate with the
number of licensed ambulance vehicles in accordance with the EAS/MTS
Regulations under HCSA. For example, an EAS licensee shall have a service crew
comprising at least 2 appropriately qualified staff for each vehicle:

a) At least one qualified emergency ambulance driver; and

b) At least one crew leader who is an appropriately qualified Ambulance
Paramedic, Ambulance Nurse or Ambulance Doctor.

Can in-training personnel (i.e. pending certification/qualification) be counted

towards the minimum requirement for ambulance service crew?

• Trainees / other staff not stipulated in the Regulations will not count towards fulfilment
of the minimum requirements for ambulance service crew.

Part 4 Requirements for Conveyance and Equipment

What are the technical requirements that each ambulance vehicle must meet?

• The Land Transport Authority (LTA) requires all vehicles, including EAS and MTS
vehicles, to be registered for use in Singapore and to comply with the registration and
technical requirements set out in the Road Traffic Act and its subsidiary legislations
under the Goods Vehicle class.

Is there any vehicular requirement for ambulances under the new regulations?

• Under HCSA, the vehicular requirements for ambulances which was previously stated
in the 2017 Standards for EAS & MTS will be promulgated into the EAS and MTS
Regulations and accompanying licensing terms and conditions. The vehicle must also
be able to accommodate: (a) the conveyance of lying and/or seated patients, and
should not compromise their safety, or the safety of the ambulance crew at any time;

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and (b) all mandatory equipment and manpower without compromising safety or care
of both patient/s and crew of the ambulance.

For PAOs who are already currently on board the VAS, would they still need to
be re-inspected prior to the implementation of HCSA?

• MOH may conduct inspections/audits on PAOs following the VAS accreditation to

assess compliance to the Standards. Accredited PAOs must ensure continued
adherence to the Standards ahead of the regulations for PAOs coming into force.

Part 5 Provision of Healthcare Services

[Updated as at 10 Aug 2021] In the event that an MTS patient deteriorates into
an emergency condition, what should the MTS provider do?

• The MTS crew should check with their CGO to determine whether they should
proceed with the conveyance, or to stop the vehicle and focus on instituting the
necessary clinical measures while activating SCDF for more advanced clinical
support. In making this assessment, the CGO and MTS crew should take into
consideration their ability to achieve the best care outcomes for the patient.

[Updated as at 10 Aug 2021] How should the licensee determine which hospital
to send patients to?

• PAOs are required to develop and institute a clear triaging framework to determine
the acuity of a patient’s medical condition (e.g. whether the patient is an Emergency
or a non-Emergency Patient) before conveying the patient.

• PAOs must transport: (a) Emergency Patients who are either already in a state of
cardiovascular collapse, or in imminent danger of collapse to the nearest public
hospital with an A&E department. The requirement applies even if the patient or
patient’s next-of-kin insist on going to a private hospital; and (b) all other Emergency
Patients to the nearest public hospital with an A&E department that possesses the
appropriate on-site specialties (e.g. adult cases to the nearest public general hospital,
and paediatric cases to National University Hospital or KK Women’s and Children’s
Hospital, whichever is nearer), unless the patient or patient’s next-of-kin have given
an indication to be ferried to a hospital of their choice.

• With the exception of the above scenarios for Emergency Patients, PAOs should
develop a process to determine what is an appropriate hospital to convey the patient
to at any point in time. This should take into account the patient’s condition, the
specialties which the hospital has, as well as the times when these specialties are
available (e.g. whether the specialties in question are available on site at the time
when the patient is estimated to arrive at the hospital).

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• To avoid disputes with the patient and/or the patient’s next-of-kin over the destination,
licensees are encouraged to clarify the above requirements, such as through a
disclaimer on their website or as part of the triaging process.

[Updated as at 19 Oct 2021] What does a proper handover of a patient entails?

• The service crew should ensure the pertinent information relating to the patient is
communicated as appropriate.

• There should be timely and adequate communication of clinical information to

facilitate proper handover to ensure no gaps arising from the patient handover. The
overall responsibility for the patient resides with the licensee and will only cease upon
complete patient handover and acknowledgement of takeover from the receiving
party.

[Updated as at 10 Aug 2021] Does HCSA regulate the pricing of private

ambulance services?

• While the HCSA Regulations do not regulate the fees and charges of healthcare
services, there are requirements for all licensees, including PAOs, to publish common
charges for services they provide (e.g. displaying their fees prominently on their
official website) and provide transparency to the bill components. PAOs are to ensure
alignment in their published fees and the actual fees charged to patients in relation to
the service(s) provided.

• To bring about greater price transparency for consumers, MOH has worked with the
accredited PAOs to publish a range of fees, with corresponding line items of the
typical types of services/procedures. The range of fees is available on MOH website:
https://www.moh.gov.sg/licensing-and-regulation/accredited-private-ambulance-
operators. PAOs licensed under HCSA will also be required to submit information on
itemised charges for the purposes of updating the range of fees published on the
MOH website.

In the event of an emergency which involves a first-time patient, how are we

able to convey the common charges before accepting the patient and prior to
actual conveyance?

• PAOs would have to inform patient or the patient’s next-of-kin of the common charges
before the service is engaged.

• Common charges include (a) base fee, (b) extra service charges (if any), (c)
consumables (e.g. oxygen, bandages, drugs, equipment use, continuous monitoring).
The patient or the patient’s next-of-kin should also be informed of the option of
conveyance with or without extra service charges (if any) and be allowed to make a
choice unless the extra service charges are required for life-saving measures.

• The patient or the patient’s next-of-kin should be notified promptly if there are changes
to the earlier conveyed charges and the patient or the patient’s next-of-kin should

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agree to the revised charges. Informed consent should be taken upon arrival prior to
the conveyance of the patient. As part of the informed consent taking, PAOs should
clearly communicate the updated rates associated with the changes in the treatment
plan and obtain a signed agreement from the patient or the patient’s next-of-kin, to
consent to the new charges before proceeding to continue with the provision of
service and charge the new rates.

[Updated as at 19 Oct 2021] In the event of a disagreement by the patient or

next-of-kin to the higher or additional charges arising from the assessment of
the patient’s condition on arrival and prior to conveyance, what should the
licensee do?

• The licensee must present alternative arrangements for the patient to seek the
necessary medical attention if the licensee does not intend to convey the patient to
the intended location. If the licensee is handling an emergency patient, the licensee
must also continue to provide clinical care and monitoring to the patient until the
receiving party takes over the patient. Examples of alternative arrangements include
contacting another licensee with the relevant competencies to manage such cases or
contacting SCDF if the patient’s condition warrants a conveyance in an emergency
ambulance.
• Do note that the overall responsibility for the patient resides with the referring licensee
and will only cease upon complete patient handover and acknowledgement of
takeover to the party that is taking over care of the patient.

[Updated as at 25 Nov 2021] How should I go about obtaining signed

acknowledgement on the charges that are applicable to the patient in the event
of an emergency?

• The licensee must obtain the signed acknowledgement from the patient or patient’s
next-of-kin in relation to the charges that are applicable to the patient.

• However in emergency situations where it is impracticable to obtain signed

acknowledgement from the patient or patient’s next-of-kin, licensees should proceed
to perform urgent life-saving measures.

Part 6 Regulatory Controls on PAOs and Vehicles

What aspects of the EAS and MTS will be inspected under HCSA?

• The inspection will be conducted in reference to the EAS and MTS Regulations under
HCSA. As such, operators may use that as a guide to prepare their fleet of vehicles
for inspection and relevant documents, policies and procedures for review.

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When and how will inspections/audits be conducted on private ambulance

services?

• Under HCSA, inspections/audits of PAOs will be conducted to assess compliance to

the HCSA regulations. Inspections/audits may be conducted for the following
scenarios: (a) prior to issuance of new EAS/MTS service licences; (b) prior to
renewing an existing EAS/MTS service licence; and (c) following notification of
changes made to the existing EAS/MTS service licence (e.g. addition of new and/or
different types of vehicles, and >50% change in the management of the ambulance
company). MOH may also conduct post-licensing or ad-hoc compliance checks on
PAOs at any time during the service licence period.

[Updated as at 10 Aug 2021] What are the disciplinary actions that can be taken
on accredited / licensed PAOs for non-compliance?

• PAOs who are currently accredited under the VAS and fail to comply with the
standards may have their VAS status revoked. They would have to either re-apply to
be accredited under VAS again prior to the EAS and MTS regulations coming into
force under HCSA or apply for a licence in order to provide EAS and/or MTS services
under HCSA. PAOs with VAS status revoked will also be removed from the list of
PAOs who has met the requirements for VAS, which is currently published on MOH’s
website for public reference. To date, the VAS status of several PAOs has been
revoked due to non-compliances to the standards detected from audits.

• Under HCSA, PAOs may have their service licence suspended or revoked, be fined
up to $20,000, and/or be given up to two years’ imprisonment for non-compliance.

What are the disciplinary actions that can be taken for unlicensed PAOs
operating under HCSA?

• PAOs who are found to be providing private ambulance services without a valid
service licence will be fined up to $20,000, and/or given up to two years’
imprisonment.

Part 7 Miscellaneous

What should I do if I wish to import an EAS/MTS vehicle for use in Singapore?

• As an operator, you are required to inform Customs and LTA of the intention to import
EAS/MTS vehicles. Once the vehicle(s) arrives in Singapore, you must declare the
import permit to Customs and apply to MOH for vehicle inspection within three months
of the vehicle(s) arriving in Singapore. The vehicle(s) must be retrofitted in
accordance with the EAS/MTS Regulations and any other accompanying regulatory
requirements under HCSA. Upon successful inspection, the details of the approved
vehicle will be included in the HCSA licence and you may then proceed to inform
Customs and register the vehicle(s) with LTA.

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Will EAS and MTS vehicles have free parking?

• All car parks are managed by private entities. As such, free parking for EAS and MTS
vehicles will be at the discretion of the car-park operator.

[Updated as at 10 Aug 2021] Are PAOs allowed to loan licensed EAS/MTS

vehicles to another licensed PAO?

• PAOs, when engaged by clients/patients to provide EAS/MTS, are not allowed

to use another PAO’s vehicles for the service, as the unique details of each
EAS/MTS vehicle is tied to the licence held by the PAOs and the PAOs will be held
responsible/accountable for all activities undertaken by the EAS/MTS vehicles
under their licence. Under HCSA, it is an offence to operate an ambulance vehicle
with a vehicle registration number that is not reflected on the licensed PAO’s licence.

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