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The MIA of Russia takes a controversial position regarding the validity of medical documents of foreign citizens 22.04.2022

Dear colleagues,
 
At the moment, the Main Directorate of the Ministry of Internal Affairs of Russia is sending controversial written explanations regarding the validity of the results of a medical examination passed by foreign citizens before March 1, 2022. According to the answers we received from the Ministry of Internal Affairs of Russia, the official position of the department is as follows: “the procedure for conducting the specified medical examination was approved by order of the Ministry of Health of Russia dated November 19, 2021 No. 1079n, which entered into force on March 1, 2022; certificate, medical report No. 1 and medical report No. 2 are valid for 12 months from the date of their issue, including in the case of passing this medical examination before March 1, 2022.”
 
Such conclusions of the department seem unfounded to us.
 
Please note that all medical documents that foreign citizens received before March 1, 2022 based on the results of a medical examination were drawn up in accordance with the Procedure for passing a medical examination in force at that time, approved by Order of the Ministry of Health of Russia dated June 29, 2015 N 384n. This procedure regulated the form and validity of medical documents of foreign citizens until March 1, 2022, and according to it, the certificate and medical report were valid for 3 months from the date of their issue. No changes were made to this legal act that would affect the validity of documents issued in accordance with this procedure.
 
But in accordance with the new procedure approved by the Order of the Ministry of Health of Russia of November 19, 2021 No. 1079n (as amended on February 21, 2022), registered with the Russian Ministry of Justice on November 30, 2021, but valid only from March 1, 2022, the validity of documents that a foreign citizen receives according to the results of a medical examination, is already 12 months.
 
Therefore, we believe it is correct to consider that documents issued based on the results of a medical examination before March 1, 2022 are valid for 3 months from the date of the examination.
 
Confidence Group draws your attention to the fact that the answers of the Ministry of Internal Affairs of Russia are not an official legal act, and therefore, in order to minimize migration risks, we strongly recommend that you provide the results of a repeated medical examination to the Ministry of Internal Affairs:
  • within 30 calendar days after the expiration of 3 months from the date of the previous medical examination, if the previous examination was carried out before March 1, 2022;
  • within 30 calendar days after the expiration of 12 months from the date of the previous medical examination, if the previous examination was carried out after March 1, 2022.
We also sent a request to the Ministry of Internal Affairs of Russia to clarify the grounds in connection with which the department considers that the results of a medical examination of foreign citizens are valid for 12 months from the date of their issue if this medical examination is passed before March 1, 2022.
 
We will notify you immediately about the response received from the Ministry of Internal Affairs.
 
For more information, please contact the consultants of the company Confidence Group.
 
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