Doctors who prescribe medicines to patients they’ve only interacted with via text, email or online asynchronous appointments should be prepared to justify their actions, the Medical Board warns.
The board, which is supported by AHPRA, laid out its stance on telehealth-only medicine in a draft set of new guidelines for telehealth consults.
The current guidelines for technology-based consults have not been updated since 2013.
Most of the proposed changes are relatively minor – e.g. changing the terminology from “technology-based consultations” to “telehealth” and shuffling the order of sections – but the section on prescribing without live consulting is brand new.
It appears to zero in on a certain style of telehealth that has been adopted by some corporates.
Practice that is not supported by the board “includes requests for medication communicated by text, email or online that do not take place in real time and are based on the patient completing a health questionnaire but where the practitioner has never spoken with the patient,” it said.
“Any practitioner who prescribes for patients in these circumstances must be able to explain how the prescribing and management of the patient was appropriate and necessary in the circumstances.”
While there isn’t a direct penalty associated with bad practice, the board did not rule out the potential for consequences.
“In terms of consequences, there is not an algorithm that links a specific action and consequence,” a spokesman told Wild Health. “Medical practice is more nuanced than that.
“Every case is considered on its merits, because every patient-doctor interaction is unique … the impact on a doctor’s practice (through their registration) is linked to the level of risk posed to patients.”
This isn’t the first move by the regulator to rein in telehealth-only services.
In October, the board imposed conditions on the registration of InstantScripts founder Dr Asher Freilich.
InstantScripts advertises its services as a quick and convenient way to manage health services online. Patients can use the site to request scripts for specific medicines via a “digital consultation”, which is essentially a questionnaire. This is forwarded to an InstantScripts doctor, who has the option to either decline the request or write the script.
It also offers phone appointments.
The conditions on Dr Freilich’s registration require him to submit to six-monthly audits of his cosmetic injectable, antibiotic, antidepressant, HIV preventative, cardiac medicine and hormone treatment prescribing habits.
He also had to complete 12 hours minimum of education, as well as a reflective practice report in relation to his practices around clinical assessment, history taking, treatment planning and prescriber obligations in each jurisdiction.
Although InstantScripts appears to offer some MBS- and PBS-subsidised services, other telehealth-only companies operate completely privately.
Women’s reproductive health service Kin, for example, doesn’t offer any government-subsidised services, citing Australia’s telehealth regulations as the reason.
A side effect of this is that it effectively puts the service out of reach of a body like the PSR, which can only investigate what Medicare asks it to.
The draft telehealth guidelines are open for consultation until Friday 17 February.