AHPRA walks back telehealth prescribing wording

The Australian Health Practitioner Regulation Agency (AHPRA) has now amended its website to clarify that good practice prescribing via telehealth can occur ‘where you’ve had a face-to-face, video or telephone consultation with the patient’.
 
A previous version of a statement released less than 48 hours prior to flag expanded telehealth advice for ‘all practitioners’ said good practice constituted ‘only prescribing if you’ve consulted with the patient face-to-face before’.
 
The advice initially prompted a report considering the implications for online prescribing business models that have proliferated in recent years.
 
On Tuesday, newsGP queried the difference between that and the existing Medical Board of Australia (MBA) guidelines, which AHPRA had described as ‘consistent’ with its updated advice.
 
The MBA guidelines came into effect in September 2023 and stipulate:
 
‘Prescribing or providing healthcare for a patient without a real-time direct consultation, whether in-person, via video or telephone, is not good practice and is not supported by the Board.’
 
An AHPRA response issued on Wednesday morning did not acknowledge the discrepancy.
 
‘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,’ a spokesperson told newsGP.
 
Subsequently, newsGP approached two medical indemnity organisations for their views on the update and whether it would affect GPs’ practice, particularly those working in telehealth. One of those organisations said they were seeking clarification from AHPRA.
 
By Thursday morning, the wording had been changed on AHPRA’s website.
 
‘The media release issued on Tuesday contained examples of good practice, including, but not limited to, only prescribing where you’ve consulted with the patient face-to-face before,’ an AHPRA spokesperson said on Thursday evening. 
 
‘This example intended to reflect that telehealth won’t be appropriate in all cases, and sometimes an in-person consultation is needed to enable fulsome assessment.
 
‘The guidance reflects that good practice is dependent on the individual circumstances of the patient and the treating environment, and it is up to the treating practitioner to determine whether in-person, video or telephone consultation is appropriate.
 
‘As highlighted in the guidance, when telehealth is being used for an initial consultation before prescribing the expectation is that the consultation happens in real time, rather than by text, email or questionnaire.
 
‘We’ve updated the media release to clarify the given example and include that it may also be by “video or telephone consultation”.’
 
They also confirmed there is no change to the guidelines from the Medical Board of Australia.
 
In its position statement on telehealth and general practice, the RACGP outlines its support for ‘telehealth services that provide continuity of care between a patient and their usual GP or general practice, including other members of general practice multidisciplinary teams’.
 
The college also states that it ‘considers telehealth to be complementary to, rather than a substitute for, face-to-face care’.
 
In recent months, AHPRA has taken a series of steps, including this week’s update, designed to cut down on widespread inappropriate prescribing in so-called vertically integrated clinics, particularly involving medicinal cannabis.
 
The regulator was established in 2010 to implement a new national registration and accreditation scheme for health practitioners, replacing previous state and territory regulatory bodies.
 
Its initial CEO Martin Fletcher stepped down last year. He was replaced by Justin Untersteiner in April, who said his priority was to put in place a ‘holistic review and major transformation’ of the notification system.
 
‘For there to be trust in our system, our notification system must be timely and efficient, it must be transparent with strong and clear communication, and it must demonstrate high levels of procedural fairness,’ he said earlier this year.
 
Original newsGP query, 12.24 pm Tuesday 7 October:
 
I am getting a newsGP story ready on this [AHPRA media release – ‘Patient safety paramount in updated telehealth guidance’] and have a further question.
 
The information online says this updated telehealth guidance is ‘consistent with the Medical Board of Australia’s’ guidelines’.
 
It also describes good practice as “only prescribing if you’ve consulted with the patient face-to-face before”.
 
However, this seems to go further than the current MBA guidelines.
 
Their precise wording is as follows:
 
Prescribing or providing healthcare for a patient without a real-time direct consultation, whether in-person, via video or telephone, is not good practice and is not supported by the Board.
 
There is no mention of a prior face to face consultation, so there seems to be room for confusion over this. Are you able to clarify?
 
I can hold publishing until around 4pm to wait for a response.
 
Thanks very much.
 
Full response from an AHPRA spokesperson, 9.41am Wednesday 8 October:
 
‘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.’ 
 
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