Dr David Kosenko, President of the Cosmetic Physicians College of Australasia (CPCA), outlines the new requirements for ‘telehealth’.

The SARS-CoV-2 pandemic which started in 2020 changed many things, including aspects of medicine and in particular General Practice. The rapid pivot from face to face to remote consulting occurred almost overnight. The clinical need to be able to provide consultations both on the phone and via video became a necessity as the waves of infection spread throughout the community.

Along with this came the practical issues of providing prescriptions and investigation requests remotely. Three years later, these adaptations have become part of mainstream medicine and day to day life for generalists and specialists alike. This has necessitated a review of the guidelines regarding what we now colloquially call ‘telehealth’.

Historically, telehealth consultations primarily occurred between a specialist and the patient in situations where the patient could not attend the specialist’s consulting rooms because of distance or immobility. These consultations were most commonly hosted by the patient’s GP, creating a three-way consultation.

General practitioners rarely provided remote consultations as there was no Medicare rebate available for this service. The COVID pandemic created a need for GPs to be able to connect with their patients to provide ongoing care if the patient was unable to attend because of quarantine requirements.

Telehealth and remote prescribing has been commonplace in cosmetic medicine for many years in order to satisfy TGA requirements to enable a doctor to delegate a procedure using a scheduled medication to a registered nurse. The guidelines regarding this type of prescribing should now comply with the 2023 edition of Guidelines for Medical Practitioners who Perform Cosmetic Surgery and Procedures and the Guidelines: Telehealth Consultations with Patients. The former guidelines have already been discussed at length in many articles and at recent conferences. The latter ones have not, and many cosmetic doctors and nurses are unaware of their existence.

The guidelines are thankfully brief, being only five pages long. The document provides a background into telehealth and reminds doctors that they must also comply with ‘Good medical practice: a code of conduct for doctors in Australia’. The most important requirements in the document are:

  • An explanation of the requirements for a telehealth consultation, including obtaining patient consent for the consultation as well as financial consent.
  • Ensuring the use of a system that enables secure access to patient records to record notes and provide prescriptions or referrals.
  • The ability to assess the appropriateness of using a telehealth consultation and be able to make arrangements to see the patient face to face should the clinical need arise.
  • Highlighting that providing healthcare without a real-time consultation or by using asynchronous requests is not supported. An asynchronous consultation is one where the consultation occurs via text, email or live-chat that does not take place in the context of a real-time, continuous consultation. These consultations are often based on a patient completing a health questionnaire and never having spoken with the doctor.
  • A reminder to ensure that as a doctor, you are legally allowed to consult with a patient intestate or overseas.

Lastly, the guidelines discourage the prescribing or providing of healthcare to a patient if you have not previously had a real time consultation with them.

These guidelines are a timely update and attempt to provide a framework for all doctors to work within whether they are general practitioners, specialists, or cosmetic doctors. They provide clarity as to the standards that the Medical Board of Australia requires doctors in Australia to follow and need to be used in conjunction with the many other guidelines previously published.

The new guidelines can be found at: www.medicalboard.gov.au/Codes-Guidelines-Policies/Telehealth-consultations-with-patients.aspx. AMP

‘Guidelines: Telehealth Consultations with Patients’ came into effect on 1 September 2023. This is the last of the trio of new guidelines released by the Medical Board of Australia and Ahpra in 2023.

Dr David Kosenko is the current President of the Cosmetic Physicians College of Australasia (CPCA).
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