Technology solutions for private clinics and doctors: from e-invoicing to electronic medical records

Over roughly an 18-month window, private clinics and independently practicing doctors in Vietnam have to handle three new compliance obligations at once, each from a different piece of legislation, all landing on the same group: Decree 70/2025/NĐ-CP (effective June 1, 2025) requires household businesses — including privately practicing doctors — with annual revenue of 1 billion VND or more to issue e-invoices generated from cash-register systems; Resolution 68-NQ/TW abolishes presumptive tax no later than 2026, forcing self-declared revenue reporting starting January 1, 2026; and Circular 13/2025/TT-BYT sets a December 31, 2026 deadline for non-hospital medical facilities — including private clinics with observation beds, day-treatment, or outpatient care — to roll out electronic medical records. Meanwhile, most small private practices and independent doctors are still running on paper logs, Excel files, and appointments booked over Zalo messages.

Three compliance obligations converging at once

**E-invoicing and the end of presumptive tax.** The same legal framework we analyzed in our post on e-invoicing for small household businesses applies directly to private practices registered as household businesses. Some guidance from healthcare-software vendors mentions an additional invoice-timing rule specific to medical services — issuing the invoice when the service ends or when payment is received, whichever comes first — but this is a vendor interpretation we couldn't directly verify against the primary legal text, so we flag it as something doctors should confirm with their accountant or tax office rather than as verified fact.

**Electronic medical records.** Circular 13/2025/TT-BYT sets a two-stage roadmap: hospitals had to finish by September 30, 2025; other medical facilities — including private clinics — have until December 31, 2026. Actual progress is inconsistent across sources: one figure cites roughly 142 public and private hospitals having gone fully paperless, while a Thanh Hóa provincial health department source reports only around 50 hospitals converted, with the Ministry of Health reportedly proposing to adjust the roadmap. For private clinics — which have far fewer IT resources than hospitals — the gap between the deadline on paper and actual rollout capacity is worth taking seriously.

**Operating license.** Decree 96/2023/NĐ-CP, implementing the 2023 Law on Medical Examination and Treatment, sets licensing conditions across three categories: staffing, facilities, and medical equipment. We found no mandatory IT-system requirement in this decree — meaning the digitization pressure comes separately from Circular 13/2025/TT-BYT and Decree 70/2025, not from the practice-licensing conditions themselves.

Why scaled-down hospital software isn't the answer for a one-doctor practice

The same logic we laid out when designing ERP Ecosystem One for one-person companies applies here: a large hospital's EMR software is built for dozens of departments, multi-level approval workflows, and a dedicated IT team to run it. A 1-2 doctor practice has no IT team, no cross-department approval process, and no reason to pay license fees for features it will never use. Trying to "shrink" a hospital system down to this scale leaves all the configuration complexity in place without solving the actual problem an independent doctor has.

Three real pain points for small practices

**First: manual scheduling leads to double-bookings and missed appointments.** A paper logbook or back-and-forth Zalo messages between doctor and patient has no mechanism to flag a time-slot conflict and no automatic reminder before the appointment date — resulting in no-shows or two patients showing up for the same slot.

**Second: scattered paper records make it slow to look up visit history.** When a patient returns after a few months, the doctor has to dig through paper files or scattered Excel sheets instead of pulling up visit history, prescriptions, and prior test results in seconds.

**Third: new e-invoicing and tax-declaration obligations go beyond a doctor's accounting knowledge.** Doctors are trained to practice medicine, not to figure out which revenue threshold triggers mandatory e-invoicing or how to connect a cash register to the tax authority — that regulatory burden needs to be carried by the software, not worked out by the doctor between patient appointments.

A consolidation architecture: four minimal modules around one patient record

• **Scheduling & automatic reminders** — patients book via a link or Zalo OA, the system auto-blocks time conflicts and sends reminders 24 hours ahead, cutting no-shows without the doctor manually texting anyone
• **A minimal electronic medical record** — exactly the data fields required under Circular 13/2025/TT-BYT for a private-practice scale (not the full multi-department hospital workflow), with a patient's visit history searchable in seconds
• **Automatic e-invoicing under Decree 70/2025** — generated from a phone or cash register, connected directly to the tax authority, using the same offline-first architecture and automatic revenue-threshold tracking we applied for small household businesses — warning the clinic before it approaches a threshold that raises its tax obligations
• **Optional AI-assisted results reading** — for clinics handling a high volume of ultrasound/lab results, the KonexForge Health Insight architecture we're developing can be added as a support tool — not a replacement for the doctor's decision

Rolling out within a private practice's actual budget

Four modules sounds like a large project, but they don't need to launch together. Under the same Module Sprint tier (3-4 weeks, 1-2 senior engineers) we apply for small household businesses, a private practice can start with whichever module hurts most — usually scheduling or e-invoicing — then expand into electronic medical records as the December 31, 2026 deadline approaches, instead of investing in a complete system from day one.

Conclusion

Three new compliance obligations — e-invoicing, the end of presumptive tax, and electronic medical records — are converging on exactly the group with the fewest IT resources: small private clinics and independently practicing doctors. The right answer isn't a shrunk-down hospital system — it's designing from scratch at the actual scale that matters: four minimal modules around one patient record, rolled out to match each clinic's real budget and urgency. Learn more about KonexForge's Development capability, or get in touch if your practice needs a compliant solution without paying for a hospital-grade system.