📝 Salient points from the Telemedicine guidelines for Family Physicians 🖱️by Dr. Devashish Saini, @RossClinics

Devashish_Saini

📜 General

  • A Registered Medical Practitioner is entitled to provide telemedicine consultation to patients from any part of India
  • The RMPs should exercise their professional judgment to decide whether a telemedicine consultation is appropriate in a given situation or an in-person consultation is needed in the interest of the patient.
  • The RMP shall uphold the same standard of care as in an in-person consultation but within the intrinsic limits of telemedicine.

📲 Initiating a Teleconsultation

  • An RMP should verify and confirm patient’s identity by name, age, address, email ID, phone number, registered ID or any other identification as may be deemed to be appropriate. The RMP should ensure that there is a mechanism for a patient to verify the credentials and contact details of the RMP.
  • For issuing a prescription, the RMP needs to explicitly ask the age of the patient, and if there is any doubt, seek age proof.
  • Where the patient is a minor, after confirming the age, teleconsultation would be allowed only if the minor is consulting along-with an adult whose identity needs to be ascertained.
  • Every RMP shall display the registration number on prescriptions, website, electronic communication (WhatsApp/ email etc.) and receipts etc. given to his/her patients.
  • Considering the situation, using his/her best judgment, an RMP may decide the best technology to use to diagnose and treat.
  • Patient consent is necessary for any telemedicine consultation. The consent can be Implied or Explicit.

⚕️ During the Consultation

  • RMPs must make all efforts to gather sufficient medical information about the patient’s condition before making any professional judgment.
  • Telemedicine has its own set of limitations for adequate examination. If a physical examination is critical information for consultation, RMP should not proceed until a physical examination can be arranged through an in-person consult. Wherever necessary, depending on professional judgement of the RMP, he/she shall recommend:
    • Video consultation
    • Examination by another RMP/ Health Worker ;
    • In-person consultation
  • RMP shall maintain all patient records including case history, investigation reports, images, etc. as appropriate
  • First consultation with a patient should be a video consultation. First Consultation means
    • The patient is consulting with the RMP for the first time; or
    • The patient has consulted with the RMP earlier, but more than 6 months have lapsed since the previous consultation; or
    • The patient has consulted with the RMP earlier, but for a different health condition
  • If the condition can be appropriately managed via telemedicine, based on the type of consultation, then the RMP may proceed with a professional judgement to:
    • Provide Health Education as appropriate in the case; and/or
    • Provide Counseling related to specific clinical condition; and/or
    • Prescribe Medicines

💊 Prescribing Medicines

  • Prescribing medications, via telemedicine consultation is at the professional discretion of the RMP. It entails the same professional accountability as in the traditional in-person consult.
  • List O medicines (OTCs like paracetamol, cough lozenges, ORS, supplements, ) may be prescribed without restrictions, to new or followup patients.
  • List A medicines: Eye/ear/nose drops/ointments/lotions, to be prescribed to new patients only after a video consultation; also includes common medicines for common chronic illnesses, which can be continued as per previous prescription
  • List B medicines: These medicines can be added on to routine chronic care medications.
  • Prohibited medicines: Not to be prescribed over teleconsultation, includes narcotics, psychotropics, Schedule X drugs.
  • See Annexure in the original document for a full list of List O, A and B medicines. These lists may be modified in the future by government notifications.

 ✍️ The Prescription

  • If the RMP has prescribed medicines, RMP shall issue a prescription as per the existing laws. RMP shall provide photo, scan, digital copy of a signed prescription or e-Prescription to the patient via email or any messaging platform
  • In case the RMP is transmitting the prescription directly to a pharmacy, he/she must ensure explicit consent of the patient that entitles him/her to get the medicines dispensed from any pharmacy of his/ her choice
  • Prescribing medicines without an appropriate diagnosis/provisional diagnosis will amount to professional misconduct

🤐 Ethics and Privacy

  • Principles of medical ethics, including professional norms for protecting patient privacy and confidentiality as per IMC Act shall be binding and must be upheld and practiced.
  • RMPs should ensure that reasonable degree of care is undertaken during hiring technology services.
  • Some examples of actions that are not permissible:
    • RMPs insisting on Telemedicine, when the patient is willing to travel to a facility and/or requests an in-person consultation
    • RMPs misusing patient images and data, especially private and sensitive in nature (e.g. RMP uploads an explicit picture of patient on social media etc)
    • RMPs who use telemedicine to prescribe medicines from the specific restricted list
    • RMPs are not permitted to solicit patients for telemedicine through any advertisements or inducements
  • It is incumbent on RMP to maintain the following records/ documents for the period as prescribed from time to time:
    • Log or record of Telemedicine interaction (e.g. Phone logs, email records, chat/ text record, video interaction logs etc.).
    • Patient records, reports, documents, images, diagnostics, data etc. (Digital or non-Digital) utilized in the telemedicine consultation should be retained by the RMP.
    • Specifically, in case a prescription is shared with the patient, the RMP is required to maintain the prescription records as required for in-person consultations.
  • Telemedicine consultations should be treated the same way as in-person consultations from a fee perspective: RMP may charge an appropriate fee for the Telemedicine consultation provided. An RMP should also give a receipt/invoice for the fee charged for providing telemedicine-based consultation.

🚑 Emergency

  • In all cases of emergency, the patient MUST be advised for an in-person interaction with a Registered Medical Practitioner at the earliest. However critical steps could be life-saving and guidance and counseling could be critical. For example, in cases involving
    trauma, right advice and guidance around maintaining the neck position might protect the spine in some cases. The RMP, based on his/ her professional discretion may
    • Advise first aid
    • Counseling
    • Facilitate referral
    • in addition to advising patient to seek an in-person consultation at the earliest.

💡 More information

The guidelines also have suggestions on workflows for new and followup consultations.

For more information and clarification on certain points, please see here

Hope this is helpful!

Dr. Devashish Saini
Dr. Devashish Saini

Founder and Family Physician, Ross Clinics

Dr Devashish Saini pursued his MBBS from AIIMS, New Delhi followed by Master of Science in Health Informatics at the University of Alabama at Birmingham. While in the US he also completed a year-long surgical internship at the University of Missouri-Columbia. He returned to India in 2008, studied entrepreneurship at the SP Jain Institute of Management and Research, Mumbai and joined Swasth India Services wherein he helped design and build low-cost low-overhead health systems for the Indian poor. He has been building and managing clinics for the last 10 years.

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