Prime minister ,during his address to nation on 19th March,2020 requested citizens to telephone doctors they are familiar with and avoid consulting them in person. That was one of the important measures to fight COVID 19 .That was when Tele Medicine(TM) was born in India in principle.
Meanwhile think-tank sat together to make this happen and the result was Tele Medicine guidelines(regulations) published on 25th March 2020.These guidelines were prepared by Board Of Governors(BOG) in supersession of Medical Council of India(MCI) in partnership with NITI Aayog.
For all those who believe in amalgamation of technology into routine medical practice ,it was a welcome ,much awaited step. From Indian perspective TM has existed for more than a couple of decades although as a fringe contributor. It helped us to deliver health care services to remote sub Himalayan region and north eastern part of the country. Its legality was questioned every now then with various possible interpretation of court verdicts related. To make the things complex a few state medical councils had advised their members regarding the practice of TM.
Current guidelines constitute appendix 5 of the Indian Medical Council (Professional Conduct, Etiquette and Ethics Regulation, 2002).In the current form guidelines are set to enable the allopathic stream of doctors to deliver health care using telemedicine. Guidelines serve the purpose of practical advices to doctors in the process of integration of TM in their normal practice of healthcare delivery.
Guidelines envisage to enable doctors to leverage TM to enhance health care service and access to all. Patient /care giver or a doctor may enter the consultation process from any part of India.
Doctors may use any real time mode(audio, video or text) or asynchronous tools(E mail, Fax) for consultation. Social networking platforms like FaceBook, chat messaging tools like WhatsApp may also be employed in addition to dedicated telemedicine platforms having advanced medical electronic and data tools. Doctor needs to apply her professional judgment to choose telemedicine and appropriate media needed as per the context.
Over the counter drugs(relatively safe and less risk of abuse) may be advised during any mode of consultation. However prescription of other medication(most of them in schedule H)may be done only during video consultation .However refill of these drugs during the follow up consultation and prescription of second line of medication for the same condition being treated may be done with telephonic(audio) and text(chat apps) consultation also.
Doctor also has the liberty to upgrade the consultation to video mode if the circumstance demands. Patient or care giver and the doctor have the right to end the consultation at any stage and decide for in person consultation.
The very act of initiating consultation from patient would mean implied consent. However, in case the consultation leads to medical prescription an explicit consent needs to be obtained during any mode of consultation. The same has to be documented by the doctor in In the files related to the patient. Explicit consent is also required when the patient is a minor or incapacitated. In case of emergency patient is advised to have in person consultation with doctor at the earliest.
A key feature of these simple guidelines is that it allows health care worker to consult with doctor for the benefit of the patients.It is easy to note that video consultation is the most preferred mode as it allows the inspection of the patient.Audio (phone) may be the simplest and quickest mode .Asynchronous modes may be employed for second opinion and in scenarios some delay is acceptable.
Doctors may also advise additional laboratory tests and scans before initiating the treatment. Doctors may provide health education during the consultation or may counsel on the specific health condition patient may have. Doctors cannot prescribe Medicines listed in Schedule X of Drug and Cosmetic Act and Rules or any Narcotic and Psychotropic substance listed in the Narcotic Drugs and Psychotropic Substances, Act, 1985 .
Doctors have to provide image(digital copy) of the signed prescription or e prescription.Doctors will not be held responsible if there is a reasonable evidence to believe that patient’s privacy and confidentiality have been compromised by a technology breach or by a person other than consulting doctor. Guidelines also appreciate the fact that a few specialties like radiology, ophthalmology and cardiology are in frontline in adoption of technology.
Guidelines advise technology platforms to conduct due diligence while onboarding doctors to their portals.AI/ML, internet of things any advanced data science based system could assist and support doctors. Technology tools cannot directly counsel or prescribe.BOG/MCI may blacklist technology firms violating the norms.
Specifications for hardware or software ,data management systems involved, standards and interoperability are excluded from the scope of these guidelines. However it may be pertinent to note that existing Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 primarily govern the practice of medicine and information technology.
To conclude guidelines are simple and practical. This is the first step in right direction having enormous potential to change the way medicine is being practiced. It is expected to play a major role in addressing inefficiency in healthcare delivery and to achieve wider access and equity.Specifically from the current Corona virus pandemic point it would reduce the burden on the tired healthcare system and will help to flatten the curve.