Information for practice managers and employers about virtual care

Virtual care is a broad term for health care services provided by practitioners to patients through digital communication channels, such as video calls, phone consultations, online messaging or similar that allows them to interact with patients without a physical presence. It can include telehealth (telephone and video-enabled), telemedicine, tele-education, teletherapy, online prescribing and telemonitoring. Virtual care does not refer to the use of technology such as voice to text notes, or automated predictive apps, and similar, during a face-to-face consultation. Not all health services are appropriate for virtual care.

All registered health practitioners can offer virtual care as long as they have the skills, competence, and software to do so and if it is safe and clinically appropriate and suitable for it to be provided to the patient.

Practitioners are also expected to assess and regularly re-assess whether virtual care is safe and clinically appropriate and suitable for both the health service being provided and for the patient.

More information is available in the National Board’s Information for practitioners who provide virtual care.

National Boards have the same expectations of practitioners using virtual care to provide health services as they do when they are delivering services face-to-face.

As an employer, you can support practitioners to deliver safe care virtually by:

• having policies and procedures about virtual care in place
• ensuring your employees have the appropriate credentialling, skills and competencies to use virtual care
• ensuring that appropriate and ongoing training in the use of virtual care is provided to relevant staff and during induction of new staff where relevant
• ensuring your employees are able to maintain clear and accurate health records for patients
• ensuring your employees can meet their ethical and legal obligations to protect the privacy of patients by
  • ensuring patients personal health information is safely stored, and
  • being aware that some technology may store information outside Australia and be subject to additional privacy legislation and requirements for regulating and storing health records
• providing appropriate technology which meets clinical requirements, patients’ needs and complies with all relevant privacy legislation and data storage requirements, including, but not limited to, legislative requirements that regulate the capture and storage of health information, including health records, patient videos and images and electronic prescriptions
• ensuring adequate technical support is available for practitioners and people seeking virtual care to troubleshoot technical issues
• ensuring your employees are able to protect patients’ privacy and right to confidentiality in their work environment (including when working from home), and
• ensuring your health service and your employees have the appropriate insurance arrangements (e.g. professional indemnity insurance) that covers virtual care consultations.

As an employer, you have an important role in supporting patients’ safe experiences of virtual care. You can support patients to have safe experiences by helping them understand what to expect from virtual care ahead of their appointments, including:

• whether a virtual care or face-to-face appointment is more appropriate, and that this decision will usually be made by their treating practitioner
• providing information on the obligations of patients and practitioners when participating in virtual care
• providing information in a way they understand, in particular, in relation to informed consent, fees, proposed treatment, sharing of information with others in their care team and if their practitioners are recording consultations
• providing information on troubleshooting technical issues
• taking all practical steps to meet the specific language, cultural, and communication needs of patients, including by encouraging employees to ask if translating and interpreting services are necessary, and being aware of how these needs may affect understanding³ and clinical care
• supporting the health and safety of Aboriginal and Torres Strait Islander patients by ensuring your systems and processes are culturally safe and that your employees engage in culturally safe practice for all virtual care consultations.
• Providing information on how they can provide feedback on the service provided

Australian registered health practitioners hold recognised qualifications and have met the registration standards to practise their profession in Australia. Their identity has been established
and they have satisfied all relevant checks, such as criminal history, and are considered to be of good standing with any other regulatory bodies they may be registered with.

It is your responsibility to ensure your employee is registered in Australia by looking them up on the public register. For larger healthcare organisations, you can become a data partner by joining Ahpra’s Practitioner information exchange (PIE).

Health practitioners located outside Australia providing virtual care to patients in Australia

If you employ an Australian registered health practitioner located outside Australia who wants to provide virtual care services to patients in Australia, you will need to consider how your clinical governance arrangements would apply in order to ensure safe and effective patient care. National Boards expect these practitioners will comply with their Boards’ regulatory frameworks including standards, codes and guidelines.

National Boards expect that health practitioners will:

• be transparent about their location outside of Australia and inform their patients about any associated risks or impacts
• ensure they have appropriate professional indemnity insurance arrangements in place for all aspects of their practice, including virtual care consultations and whether they have adequate coverage when based outside Australia
• ensure that patients’ personal health information is safely stored and be aware that it may be stored outside Australia and subject to additional privacy legislation and requirements for regulating and storing health records. You and your employees have ethical and legal obligations to protect the privacy of patients
• check with the regulatory authority for their profession in the jurisdiction they intend to practise about any registration requirements they may have, and with Australian health services and funders such as Medicare, in relation to any other requirements these bodies may have, and
• ensure they adequately maintain quality continuity of care and referral networks in Australia, to enable safe referral of patients if/when required.

Health practitioners providing virtual care to patients outside Australia

If you employ a registered health practitioner in Australia who is providing virtual care services to patients located outside Australia, be aware that they must continue to comply with their Boards’ regulatory frameworks including standards, codes and guidelines and hold appropriate professional indemnity insurance.

You and/or your employee need to check whether they are required to be registered by the relevant regulatory authority for their profession in the country where the patient is located and comply with legislative requirements in that jurisdiction, including for prescribing and professional indemnity insurance.

Information about practitioners registered outside Australia

Practitioners who are registered outside Australia are expected to be registered by the relevant National Board for their profession in Australia before providing a health service to patients located in Australia, including virtual care services. Limited exceptions may apply in circumstances where the patient is located in Australia, managed by an Australian registered practitioner and another practitioner is providing a second opinion or advice to that practitioner.

For more information, refer to the relevant National Board’s website for more information about registration, including guidance about when the Board expects a practitioner will be registered.

The Code of conduct⁴ can help employers understand what standards of conduct National Boards expect of registered health practitioners. The codes of conduct (or equivalent) apply to all registered health practitioners, including when using virtual care.

Review

This information is designed to support employers who employ registered health practitioners using virtual care. It will be reviewed and updated as required.