The Healthcare Quality Act

Marek has run a solo physiotherapy practice for three years -- he rents a treatment room, sees a dozen or so patients a week, keeps his own records, and answers his own phone. When he came across an article online about an "internal quality and safety management system," his first thought was: that surely applies to hospitals and large clinics, not a one-person business. He closed the tab and went back to work.

Was he right? It depends on one question: does his practice provide services under a contract with the NFZ (the National Health Fund). The Act of 16 June 2023 on Quality in Healthcare and Patient Safety ties the duty to have an internal system (in Polish: WSZJiB) to such a contract. In this article we read that provision directly, show what the system is supposed to cover and how to approach the topic at a small practice, including one that works purely privately.

Who is covered by the WSZJiB obligation

The key provision is Article 18(1) of the Act. The duty to have an internal system, made up of rules, procedures, methods and job descriptions, rests on an entity providing healthcare activity under a contract for the provision of healthcare services financed from public funds concluded with the Fund, that is, the NFZ. The aim of the system is to prevent adverse events.

The term "entity providing healthcare activity" is broad. The Act refers to the Act on Healthcare Activity (Article 2(1)(5)), which covers healthcare entities as well as physiotherapists practising in a professional practice. Being entered in the register does not, however, decide the duty under Article 18. The NFZ contract does.

In practice there are two situations:

• You have an NFZ contract (a solo practice or a larger entity): Article 18(1) directly imposes the duty to have and run an internal system. The Act sets no staff-size or patient-volume threshold.
• You work purely privately: we found no basis in Article 18(1) to say that this provision binds you. We also found no provision in the Act imposing WSZJiB on entities without an NFZ contract. The Act lists WSZJiB as an element of the quality system (Article 3(2)), but it ties the duty to have it to a contract with the Fund.

Whether additional circumstances apply in your case (for example requirements in the NFZ contract itself) you will find in the contract and the conditions of the procedure, which we did not examine.

What the internal system covers under the Act

Article 18(2) says that running the system consists of implementing, maintaining and improving it, on the basis of an assessment of its effectiveness and the results of patient opinion and experience surveys. Within the system the entity (Article 18(3)):

1. implements solutions for identifying and managing the risk of adverse events,
2. identifies priority areas for improving quality and safety,
3. sets the criteria and methods needed for effective supervision of the quality and safety of services,
4. periodically monitors and assesses the quality and safety of services,
5. monitors adverse events,
6. ensures access to training that builds and improves staff competence in quality and safety,
7. conducts patient opinion and experience surveys using a questionnaire.

The person responsible for running the system is the head of the entity providing healthcare activity (Article 19(1)). At a solo practice that is you. The person's tasks include, among others, analysing the root causes of an adverse event, providing the resources and information needed to monitor quality, and preparing documents setting out the rules, procedures, methods and job descriptions (Article 19(2)).

The Act defines an adverse event as an event occurring during the provision of a service, as a result of providing it or of failing to provide it, causing or capable of causing a negative effect on a patient's health or life (Article 2(8)).

What this means in practice for a small practice

The Act does not set a minimum form or size for the system, and we found no provision in it that differentiates requirements by scale of activity. It does not require external certification. You therefore adjust the scale of documents and procedures to your business, but each of the seven elements in Article 18(3) should be reflected in the practice.

For a solo practice this can be a simple but genuinely used set of tools: a short list of risks, an incident register, a periodic patient satisfaction survey and a note on what follows from those observations. For a rehabilitation center employing a dozen or so therapists it means more: periodic reviews of the data, a designated person for coordination and a documented process for implementing conclusions.

Elements of the system in a practice

Identifying and analysing patient-safety risk

This is the starting point: consciously considering which situations in everyday work could endanger a patient (Article 18(3)(1) and (2)). In physiotherapy this includes, for example, choosing treatment intensity for a patient with contraindications, patient identification errors when many people are booked on the same day, or risks related to physical-therapy equipment.

Monitoring adverse events

The system must allow you to record situations in which an adverse event occurred or could have occurred (point 5 read together with the definition in Article 2(8)). This is a separate topic, covered in our article on the adverse event register in physiotherapy, with a template and tips for solo and group practices.

Patient satisfaction surveys

Patient opinion and experience surveys are carried out using a questionnaire whose template the Minister of Health publishes in the Public Information Bulletin (Article 20(1), Article 18(3)(7)). An entity other than one providing inpatient, round-the-clock services informs patients, in a way of its choosing, of the option to complete the questionnaire (Article 20(3)). We do not settle whether Article 20(3) also applies to practices without an NFZ contract. We cover surveys in the article on the patient satisfaction survey.

Corrective and preventive action and training

Collecting data achieves little if nothing follows from it. The Act speaks of monitoring and assessing quality and of improving the system on the basis of an assessment of effectiveness (Article 18(2) and (3)(4)), and of ensuring access to staff training (point 6). Record conclusions and decisions, for example a change to the patient intake procedure after surveys showed a recurring communication problem.

The table below is our suggested scale, not a requirement of the Act:

System element	Solo practice	Rehabilitation center (a dozen or so staff)
Risk identification	Short list of main risks, reviewed once a year	Formal procedure, periodic review with the team
Adverse event register	Simple spreadsheet register, updated as you go	Register broken down by therapist, trend analysis
Satisfaction surveys	Short survey after a series of treatments	Regular surveys and aggregated summaries
Corrective action	Note with a conclusion and decision	Documented process for implementing changes across the team
Responsibility for the system	Practice owner	Head of the entity, possibly a designated coordinator

How to approach implementation

If you have an NFZ contract, do not wait for an inspection to put this in order. If you work privately, the same tools are worth having as good practice. We suggest this order:

1. List the main patient-safety risks in your everyday work: a list of a few to a dozen points, not an elaborate document.
2. Set up a simple adverse event register. Even if nothing serious has happened for years, a working tool is what Article 18(3)(5) is about.
3. Introduce a short satisfaction survey after a completed series of treatments, on paper or electronic, used systematically.
4. Record the conclusions and decisions you make on the basis of the data. Even a one-sentence note "after analysing the surveys we changed how we inform patients about waiting times" does its job.
5. Ensure access to training in quality and safety for yourself and your staff, and describe how you document it.
6. Match the scale of the system to the size of the practice. If you employ a team, add a periodic review with the therapists.

[SP] Example -- Solo practice: Marek checks his NFZ contract and confirms that he provides services under it, so Article 18 applies to him. He sets up a simple incident register in a spreadsheet and prints a short satisfaction survey that he hands to patients after the last visit in a series. Once a quarter he reviews the collected data and writes a paragraph on whether anything needs changing.

[GR] Example -- Group practice: A rehabilitation center employing twelve physiotherapists and providing services under an NFZ contract names its head of entity as the person responsible for the system and designates a coordinator. Every month the coordinator collects adverse event reports from the whole team, once a quarter the conclusions from the surveys are discussed, and decisions about procedure changes are written down and passed on to the therapists.

Authorisation, accreditation and inspections

The Quality Act also regulates authorisation (Articles 6-17) and accreditation (Article 21 et seq.). Authorisation is a condition for performing a contract for inpatient services in the profiles of the basic hospital safety net (Article 6), so it does not apply to a physiotherapy practice. Having an internal system is one of the conditions for a hospital to obtain authorisation (Article 7(1)).

We found no penal provisions in the Act for lacking an internal system, nor a separate procedure for inspecting how it is run. We did not examine how the NFZ verifies the system within contracts and inspections of providers, because that follows from other provisions and from the contract. We discuss NFZ inspections separately in the article on NFZ inspections at a physiotherapy practice. Typical gaps in a practice's paperwork are collected in the article on the most common compliance mistakes at a physiotherapy practice.

Frequently asked questions

Does a solo physiotherapy practice need WSZJiB?

It depends on the NFZ contract. Article 18(1) of the Quality Act imposes the duty to have an internal system on an entity providing healthcare activity under a contract for healthcare services financed from public funds concluded with the NFZ. The Act sets no staff-size threshold. For a practice working purely privately we found no basis for the duty in that provision.

Does WSZJiB require separate paper documentation or a certificate?

The Act does not mandate a specific document format or an external certificate. The system consists of rules, procedures, methods and job descriptions (Article 18(1)), and the responsible person prepares the documents that set them out (Article 19(2)(3)). In a small practice this can be a simple spreadsheet or a binder, as long as it is actually and systematically maintained.

What happens if there is no quality management system in place?

We found no penal provisions or sanctions for lacking a system in the Quality Act. Consequences may follow from other provisions and from the NFZ contract, which we did not examine. In practice, a lack of documented activity makes it harder to demonstrate diligence when a patient complaint arises.

Where is the best place to start implementing WSZJiB in a small practice?

The simplest starting point is an adverse event register and a short patient satisfaction survey after a completed series of treatments. These two elements give you real material to analyse with little effort, and only on that basis is it worth expanding the system with further procedures.

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Legal status as of: 3 November 2026

Legal basis: Act of 16 June 2023 on Quality in Healthcare and Patient Safety (Journal of Laws 2023 item 1692, as promulgated; we found no consolidated text), Articles 2(8), 3, 6, 7, 18-20; Act of 3 July 2026 amending the Act on the National Oncology Network and certain other acts (Journal of Laws 2026 item 1007), Article 4 (amends Articles 22(6) and 24 of the Quality Act, does not concern Articles 18-20); Act of 15 April 2011 on Healthcare Activity (consolidated text Journal of Laws 2026 item 156; the amendment in Journal of Laws 2026 item 972 concerns Article 27a), Article 2(1)(5). We did not check: the Act on healthcare services financed from public funds, the content of the NFZ contract and procedure conditions, the accreditation rules beyond a general description, the implementing regulations (including the questionnaire template) or NFZ inspection practice.

Last reviewed: 3 November 2026

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Related articles:
- NFZ inspections at a physiotherapy practice
- Most common compliance mistakes at a physiotherapy practice
- Adverse event register in physiotherapy
- Patient Satisfaction Survey Template