The regulator’s latest guidance on telehealth leads to some contradictory places.
Face-to-face consultations before prescribing are “best practice”, but consulting via video or telephone prescribing is still “good practice”, the health practitioner regulator has clarified while standing by its previous comments.
It has been a somewhat confusing week.
On Tuesday morning, AHPRA put out a media release spruiking “revised telehealth guidance” to “reflect concerns around unethical practice and emerging business models focused more on profit than patient safety”.
So far, so good.
Then came a list of “good telehealth practices”.
For clarity’s sake, it was presented like this (emphasis our own):
“Good telehealth practices include:
- sharing information in a way the patient can understand and access
- getting all necessary medical history and background information to make a diagnosis
- gaining informed consent, especially when using any supporting technologies like AI scribes
- only prescribing if you’ve consulted with the patient face-to-face before
- letting patients know when telehealth may not meet their care needs, and when they may need to access other options like in-person appointments
- confirming the patient is who they say they are.”
Before that point, AHPRA’s guidance had only ever asked practitioners to perform a real-time consultation, whether that be in-person, via video or via telephone, rather than specifying that the consult should be in-person.
This change would have been a big deal.
But the document that AHPRA actually put out did not deviate from its previous advice.
Again, for the sake of clarity, it was presented like this (emphasis our own):
“Practitioners who prescribe medicine via telehealth should:
- Be aware of and comply with relevant state, territory and jurisdictional legislative requirements for prescribing medicines. This is particularly important for registered health practitioners who prescribe medication to patients in different states or territories, which may have different legislative or regulatory requirements.
- When appropriate, comply with the use of government health and prescription monitoring services such as Prescription Shopping Programme, My Health Record, HealthNet, Real Time Prescription Monitoring platforms.
- Be aware National Boards do not support or consider it good practice to prescribe medicine or other assistive technologies (for example orthoses or glasses, or mobility aids) for a patient that a practitioner has never consulted, whether face-to-face, via video or telephone. This includes requests for medicine or other health services communicated by text, email or online that do not take place in real-time or are based on the patient completing a health questionnaire where the practitioner has not formally consulted with the patient. The Boards do not consider an online chat to be a synchronous (in real time) consultation.”
Given the somewhat contradictory messages, OR asked the regulator to clarify what it considered to be good telehealth practice and which of the two documents contained the correct information.
In its response, AHPRA appeared to back its previous advice in accepting that real-time consultations were considered good practice.
When asked to confirm that the information included in the press release – specifically that “good telehealth practice is … only prescribing if you’ve consulted with the patient face-to-face before” – was incorrect, the regulator did not reply.
Here’s what a spokesperson for AHPRA said, in full (emphasis our own):
“We use definitions of ‘good practice’ to help practitioners meet their patients’ needs and their professional obligations around quality and safety. It is informed by evidence and goes to a practitioner’s clinical judgement.
“AHPRA continues to respond to concerns around prescribing via telehealth. When concerns arise, practitioners are asked to provide further information about how they exercise their clinical judgement to meet the patient’s needs and their own professional obligations.
“While face-to-face consultations before prescribing remain best practice, there may be circumstances in which a practitioner can demonstrate that an alternative approach to that broadly defined as ‘good practice’ is, in their professional judgement, appropriate and safe.
“As technology continues to evolve, some digital tools may have legitimate uses in healthcare but the onus is on practitioners to ensure they are meeting their professional obligations. The same applies to new business models.
“The telehealth guidance is part of a suite of regulatory documents, including Codes of Conduct, developed by Ahpra and the National Boards to set out expectations for ‘good practice’ and to support informed decision-making by both practitioners and patients.”
