Download Euc’s Telehealth Best Practice Principles
The current gaps in telehealth regulation
Following rapid expansion over several years, telehealth has forged a permanent position in Australia’s healthcare landscape. While this expansion gives patients greater choice, it has outpaced the ability of existing regulators to effectively oversee the industry.
Unlike for medicines and individual health practitioners, there is currently no established framework of rules specific to telehealth clinics in Australia, nor any regulator dedicated to overseeing them (see further background here). There is also no accreditation standard, whether voluntary or compulsory, which is uniquely designed to evaluate the safety and quality of telehealth services.
As a result, there is no mechanism to require online telehealth clinics to register with any authority, undertake external review prior to launching, or comply with ongoing audits or minimum standards of clinical governance. This has the real potential to create risks for both patients and practitioners. It also deprives patients of the ability to make an informed choice about their treatment, since they have no yardstick against which to judge a given telehealth service.
To address this gap, in Eucalyptus’s view a regulatory framework should be created which includes at least:
- minimum safety and quality standards;
- an independent evaluation mechanism; and
- enforceable consequences for non-compliance.
As a step toward the first of these outcomes, Eucalyptus proposes the Telehealth Best Practice Principles for Australian Online Providers. This document not only reflects the standards to which Eucalyptus already holds itself, but is also offered as a starting point for discussion of an industry-wide code of conduct.
What do Eucalyptus’s 'Best Practice Principles' say?
The Best Practice Principles are informed by Eucalyptus’s experience with accreditation and regulation in both Australia and the UK. They are intended to provide practical and concise guidance which is specific to the online telehealth context and which is less detailed than a formal accreditation standard.
The document is divided into three parts:
- Clinical safety, quality and governance — this section covers topics such as verifying each patient’s identity and medical history, detecting inappropriate access to care, the defining and auditing of internal standards for quality and safety, and the undertaking of external evaluation via appropriate accrediting bodies.
- Good patient care — this section deals with continuity of care, including communication with each patient’s regular medical practitioner on initiation of treatment and at treatment cessation. It also covers the recording and benchmarking of patient clinical outcomes, as well as the evidentiary support for the telehealth service’s model of care.
- Data protection and security — this section covers the types of internal controls and external evaluations which should be in place to secure patients’ health data, including access controls, backups and system monitoring.
Where to from here?
An industry code of conduct alone will not solve the problem of insufficient telehealth regulation in Australia. Telehealth clinics should be mandated (or at least incentivised) to comply with such a code, and there should be tangible consequences if they do not. Moreover, there should be a mechanism for an external agency to independently review each telehealth clinic’s internal processes, to ensure that they practise what they preach.
None of this is excessive or unusual. It occurs every day — indeed, it is required — for every hospital and day clinic in Australia, while similar principles exist for community GP clinics.
The ultimate goal here should be for the general public and government alike to have confidence in the safety and quality of the telehealth sector, and for patients to be able to make informed choices about their treatment.
In the meantime, Eucalyptus supports:
- drafting an industry code of conduct providing for rigorous standards of safety and quality;
- the formation of a telehealth industry group which has a self-regulatory function as its aim; and
- the development of a tailored accreditation regime for the telehealth sector.
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