Healthcare Fields

A range of healthcare services can be provided to patients as telehealth services including:

• general practice consultations;
• specialist consultations (ranging from consultations with psychiatrists to with surgeons);
• allied health services (e.g., psychology, physiotherapy, chiropractic, podiatry, dietetics); and
• mental health services.

The Australian Government recommends videoconference services as the preferred approach for substituting a face-to-face consultation. However, audio-only services can be offered if video is not available. No specific equipment is required for the purpose of providing Medicare-compliant telehealth services.

According to the TeleHealth Commission, the term telehealth covers a broad spectrum, including but not limited to:

• telemonitoring (medical monitoring of a patient’s state of health);
• teletherapy (active intervention in the treatment of a patient);
• teleconciliations (obtaining a second opinion from another doctor); and
• teleconference (involvement of a second physician for ongoing medical treatment by a doctor).

According to the TeleHealth Commission a more developed and applied area of telehealth is the field of telemonitoring, in particular for patients with diabetes, cardiac insufficiency and abnormal levels of blood pressure.

However, there is no official list of which types of healthcare services are provided via telehealth in Austria. It depends on each individual doctor which telehealth services they wish to offer (provided the principle of directness and personal exercise are complied with as well as the data protection requirements are met).

Beside apps like Skype or Zoom, whose use within providing telehealth services is not forbidden (provided data protection requirements are met), such services can also be provided through specific e-health-applications, which can be certified by TELEMED Austria (e.g. "eedoctors-App" was officially certified since April 2020). TELEMED Austria is also hosting a register, which contains certified telehealth services providers.

The telehealth services that are available in Bahrain are as follows:

Private telehealth services

The NHRA have authorised / licensed a privately owned company to create an online platform (Licensed Platform) that offers telemedicine services (by way of high definition video consultations). The Licensed Platform offers a range of healthcare services including general practice, psychology and psychiatry, dentistry, and specialist services such as cardiology, dermatology and endocrinology.

Public telehealth services

The Information & e-Government Authority (in cooperation with the Ministry of Health and the NHRA) have introduced an application that consists of a number of health services available to the general public, including:

• Find a Doctor: displaying all authorised physicians in Bahrain, with their specialties and their healthcare premises;
• Medicines: information about the authorised medicines in Bahrain pharmacies, with related details (price and supplier name);
• Ask a Doctor: ask a medical question and receive a reply from the concerned physician;
• Appointments: book an appointment at your public health centre or Salmaniya Medical Complex pharmacy and view all available appointment slots of Salmaniya Medical Complex and King Hamad University Hospital (i.e. public hospitals in Bahrain);
• Pharmacies and Shops: information about the authorised pharmacies and health product retailers in Bahrain;
• Health Care Facilities: information about the healthcare facilities in Bahrain (hospitals, clinics, health centres);
• Medical Results: ability to view the status of medical results (lab and x-ray) in Salmaniya Medical Complex and King Hamad University Hospital; and
• Birth Certificate Services: request for birth certificates (for new births or a replacement of an existing birth certificate).

There is no specific limit on which services might be provided by way of telehealth applications.

The main difficulty is the reimbursement of telehealth costs. Regarding this issue, we refer to the test projects that RIZIV/INAMI has been carrying out to assess the feasibility of reimbursement frameworks for telehealth applications (as described under the chapters about telehealth availability, costs and anticipated reforms).

The use of technology has brought new tools that seek to help the connective aspects between patients and Health professionals, limiting face-to-face interactions. As a result, this move has brought about a truthful seismic shift in the industry, especially in how Healthcare services are delivered and enabled through technology.

Telehealth has a broad scope of features in Brazil. It includes categories such as mobile health (mHealth), health information technology (IT), wearable devices, telemedicine, telenursing, telepsychology, and personalized medicine. From mobile medical apps and software that support clinical decisions that doctors make every day to artificial intelligence and machine learning, digital technology has been driving a revolution in healthcare in Brazil in the post-pandemic era.

According to the current Brazilian Telehealth regulation (i.e., Federal Law n. 14,510/2022), telehealth has a broad definition as “the modality of providing health services at a distance by using information and communication technologies, which involves, among others, the secure transmission of data and health information through texts, sounds, images or other suitable ways”.

As for the appointments with doctors, for instance, it can be performed through general videoconferencing / teleconferencing apps like Skype, Zoom, and Microsoft Teams. The main point of concern when running an appointment digitally is with data privacy and security in relation to the patient data, including patients’ electronic health record as well as management of disease conditions outside of traditional care settings. That is why the Brazilian Telehealth regulation establishes the data privacy and the digital responsibility as principles for the provision of telehealth services, as well as the obligation to comply with the Brazilian General Data Protection Law (GDPL).

Also, considering the provision of telehealth services within the scope of the Brazilian public health system (SUS), the Brazilian Ministry of Health’s Ordinance n. 1,348/2022 establishes that the telehealth actions and services may be carried out in mobile and fixed health units (i.e., Basic Health Units or simply “UBS”) duly registered in the National Registry of Health Facilities (i.e., CNES).

It is important to highlight that all practices of healthcare provision may be encompassed by telehealth, but the feasibility of providing telehealth services to patients (i.e., if telehealth will suffice patients’ needs) depends on the health professional’s assessment. Thus, the health professional is assured the freedom and complete independence to decide on whether to use telehealth, including in relation to the first consultation, service or procedure, and may indicate the use of face-to-face care (or even opt for it) whenever deemed necessary.

No.

The types of healthcare services for which telehealth is currently available varies from province to province in Canada.

For example, in the province of Ontario, the Ministry of Health and Long-Term Care recently published billing amendments to enable direct-to-patient video visits and to modernise virtual care compensation. As of 15 November 2019, direct-to-patient video visits are eligible for delivery by the following physicians once registered with the Ministry’s Virtual Care Program for billing privileges: all specialists, general practitioners, focused practice designated physicians when providing services associated with their designation, and primary care physicians who are in a patient enrolment model ("PEM") and are delivering care to a rostered patient. Ontario also offers Telehealth Ontario, a free, confidential service Ontarians can call to get health advice or information. Telehealth Ontario is made available by the Government of Ontario. A Registered Nurse will take a call 24 hours a day, seven days a week, and assistance is available in more than 300 languages. Telehealth is only offered over the phone and email advice is not available. However, more recently, various governments have signaled they wanted physicians to return to offering more in-person care. Beginning December 1, 2022, the Ontario government began limiting public health insurance payments to doctors for virtual care, in an effort to encourage face-to-face interaction.

In British Columbia, both primary care physicians and specialists in British Columbia are able to provide a range of telemedicine services directly to patients and, since 2011, have not been restricted to using specific platforms, networks, or telemedicine facilities.

The healthcare services that have been made available to the public can be classified in four categories, depending on the particular service involved:

• Tele-Reporting: Patients can access digital copies of certain exams and / or relevant reports, to be drafted by the specialist practitioner. Tele-Electrocardiogram, Tele-Radiology and Tele-Ophthalmology are part of the services that can be found within this category of healthcare service.
• Teleconsultations in Outpatient, Inpatient and Emergency Care: This type of healthcare service is the one that is usually understood as telemedicine, and involves the provision of health services where patients and providers are separated by distance. Teleconsultation can be provided for the following specialities: Dermatology, Geriatrics, Endocrinology, Neurology, Nephrology, Diabetology and Psychiatry among others. In addition, other teleconsultations that are not provided by doctors, such as midwives, nutritionists, psychologists, medical technicians and phono-audiologists, are all allowed.
• Telemedicine in High Complexity Network and GES (Expressly Guaranteed Pathologies) Network: This modality of healthcare is associated to more complex diseases, where the health authority already counts with especial programs and networks. This category includes tele-nephrology, child neuropsychiatry, telemedicine for cancer patients, telemedicine for Extracorporeal Oxygenation Therapy for Adults, telemedicine in Cerebral Vascular Attack, telemedicine for HIV/AIDS patients, telemedicine for operable congenital heart diseases, and telemedicine for burn patients, amongst others.
• Tele-Assistance in the Health Network: This strategy offers citizens a permanent service for the delivery of information, guidance, education, assistance and support in health matters, by providing timely, equitable and quality healthcare accessed by telephone 24 hours a day, during all year. This includes, e.g., the coordination and arrangement of surgeries, the answer to health queries, and prevention issues relating to specific patient groups.

Note that the information and communication technologies to be used as a support for telemedicine services must comply with: (i) the standards of information security established by the Ministry of Health (i.e., National Program for Telehealth, and Data Safety Plan), (ii) the provisions of Law No. 20,584 on Rights and Obligations of patients; and (iii) data protection laws; and (iv) the specific COVID-19 regulations concerning telehealth in the context of the COVID-19 pandemic. In practice, the provision of healthcare services normally involves using general private videoconferencing apps, such as Zoom or Skype, or internal software developed by the relevant healthcare provider.

According to Administrative Measures for Internet Hospitals (For Trial Implementation), the practice scope of an internet hospital shall not exceed the practice scope of the offline hospital that the internet hospital is affiliated with. There are no specific limitations based on the practice areas. That said, there is a strict ban on initial diagnosis or treatment activity via internet or other information technology. Only after a physician confirms that a patient has been clearly diagnosed with certain common diseases or chronic diseases in an offline hospital, the physician might provide follow-up online consultations for the same diagnosis.

The provision of remote medical service in China involves both proprietary platforms as well as utilisation of general remote messaging tools, such as WeChat. According to the Good Administrative Practice for Remote Medical Services (For Trial Implementation), the inviter institute for remote medical services might directly invite the invitee institute to provide technical support for the inviter institute’s medical treatment activities, via e.g., telecommunications, and computer and network technology. On the other hand, the inviter institute or a third party entity might also establish a proprietary platform for the provision of remote medical service.

Telehealth has always been available for the provision of health services of any specialty. However, it is important to note that in 2022 the Ministry of Health issued an assessment and balance of the use of telehealth and telemedicine in Colombia, which stated that the most required specialties are: general medicine, psychology, internal medicine, pediatrics, nutrition and dietetics, gynecoid-obstetrics, dermatology, orthopedics, traumatology, nursing, psychiatry, neurology, physiotherapy, cardiovascular diagnostics and cardiology.

In any case, the provision of telehealth services requires prior authorisation granted by the local health authority. This authority will verify that the provider complies with the requirements for the provision of the specific health service, as well as the provision through telehealth.

Resolutions 2654 and 3100 of 2019 regulate four kinds of telehealth:

• Interactive: Real-time services provided via video call. Video calls can only be recorded with the prior and express consent of the patient, and such recording shall be included in the patient’s medical records.
• Non-interactive: Asynchronous communication for the provision of health services.
• Tele-expertise: Asynchronous or synchronous communication for the provision of health services. It can take place between:
  • two healthcare professionals in which one provides in presence attention while the other provides remote assistance;
  • a healthcare professional that provides remote assistance and a nonprofessional healthcare provider (such as technician, technologist or assistant) that provides in presence attention to the patient; or
  • healthcare professionals meeting in medical boards.
• Telemonitoring: The relationship between healthcare professionals and patients, through a technological infrastructure that records and transfers medical data and allows healthcare professionals to maintain monitoring of the patient status.

In each of the above instances, the law requires specific mechanisms for communication with the patient. The mechanism used must comply with the following rules:

• It shall ensure the information security, and particularly personal data protection, is in accordance with the applicable law. The used platforms need to have mechanisms that control access to protected information, have security certificates and encryption algorithms.
• The used platform shall comply with interoperability standards regarding the content and the data exchange.
• The provider shall ensure the reliability, integrity and availability of the information collected, generated or transferred.

According to the Network Of Telemedicine Centers Decision, Telemedicine services are available in the context of primary, secondary as well as tertiary care.

Regarding the technology, Article 30 of the Telemedicine Ordinance sets forth mandatory criteria in respect of information, communication, and computer equipment of the telemedicine centre which have to have an European certificate (CE). Those criteria are:

• uninterruptible power supply which must ensure a minimum autonomy of all components of 30 minutes;
• a computer with associated peripheral devices necessary for work; and
• information and communication devices for data transmission and protection.

Moreover, Article 31 of the Telemedicine Ordinance requires the following conditions in relation to information and communication equipment, computer equipment, and infrastructure of the telemedicine centre to be met:

• the computer network used for performing telemedicine activities must be a private computer network, without access to other computer networks and the Internet;
• the possibility of connecting the network information and communication infrastructure with other networks in order to exchange patient data. The connection must be made through a firewall in which traffic is filtered at least by destination IP addresses and ports;
• access to data in the database via any interface may only be granted to an authorised person;
• prevention of access of manufacturers and repairers of computer equipment to patient data. Such data may be accessed only by a person authorised to do so by the data owner (patient);
• the information system must be implemented with backup data storage in at least two spatially distant locations;
• backup of the information system is performed regularly on a daily basis;
• verification of backup copies of the information system is performed once every month in such a way that a fully functional information system is re-established from the backup copy;
• in audio or audio-video conferences, the audio and video delay must not exceed 150 ms; and
• data delay in the network communication infrastructure must not exceed 50 ms.

In addition, pursuant to Article 12 of the Telemedicine Ordinance, the equipment as well as information and communication infrastructure necessary for work in the basic network of telemedicine centres are to be provided by the Croatian Ministry of Health and shall obtained through public procurement mechanisms. Additionally, such equipment and infrastructure for the operation of telemedicine centres in the expanded network of telemedicine centres are provided by healthcare institutions, companies that perform healthcare activities, and private healthcare workers that perform telemedicine activities.

The Czech law already recognizes the ePrescription system regulated by the Medicines Act (Act No. 378/2007 Coll.). The ePrescription system is a central repository of electronic prescriptions and, with effect from 1 January 2022, also a central repository of vaccination records.  In short, the ePrescription system allows authorised persons to consult the patient's medication record, which contains data on prescribed and dispensed medicines, and allows them to view data on vaccinations administered to a particular patient. Another electronic tool in the field of sickness insurance is the eSick leave card, which is an electronic sickness absence report issued by a doctor. Also anchored in legislation is the so-called patient summary regulated in the Health Services Act (Act No. 372/2011 Coll.). This is an electronic set of patient data, which is intended primarily for the purpose of sharing information with health service providers in another EU country through the National Contact Point for eHealth.

The Act on electronization of healthcare represents the first phase of the electronization of healthcare. It sets forth the concept of eHealth, which includes, among other things, a central infrastructure, which is the so-called integrated data interface. Building an integrated data interface is intended to ensure uniform access to eHealth services and provides the basis for sharing information between healthcare services providers, patients and insurers. Patients will be able to access what information is held on them in registers via the eHealth portal.

The integrated data interface will include so-called core registers - a patient register, a provider register and a health worker register. The Act on electronization of healthcare also introduces and defines a patient identifier to replace birth numbers (personal identification numbers) and health care worker identifiers used in the health care system as unique identifiers of persons in the electronic health care system.  The main part of the law establishing the integrated data interface and personal identifiers will come into force on 1 January 2023.

The law also defines eHealth standards, the issuance of which is entrusted to the Ministry of Health. The obligation to comply with them will apply from 1 January 2026.

The development and implementation of telehealth has been a priority in Denmark for years. Consequently, Danish authorities have developed several digital solutions including access to a digital health platform called "sundhed.dk" and apps such as "Min læge" and "Medicinkortet", where the patient can, among other things, access their local doctor, renew prescriptions, and be reminded about medications.

New digital solutions exist in nearly all aspects of the Danish healthcare system – both public and private – and has naturally increased during the current pandemic, e.g., allowing doctors to consult their patients online as part of their general practice.

Telehealth services are currently available in some practices, such as in psychology and general practice and the use of telehealth services have been increasing. The services are commonly provided on the basis of information and documentation accessed by medical practitioners electronically, for example via video link, chat or a smartphone. Some of the services are enabled by (cloud-based) IT platform.

It should be noticed that all digital and online services, in which patient data is processed, shall be performed in accordance with the GDPR and the Act on the Status and Rights of Patients.

Types of services

The French Public Health Code (“FPHC”) defines 6 categories of telehealth procedures: (i) teleconsultation, (ii) tele-surveillance, (iii) tele-expertise, (iv) tele-assistance, (v) medical response and (vi) tele-care (see section “Telehealth Availability” above for more information).

Professionals involved

Teleconsultations may only be carried out by medical professionals (i.e., doctors, dental surgeons and midwives), although the patient may be assisted by another healthcare professional or a psychologist during the teleconsultation.

Tele-surveillance, tele-expertise and tele-assistance can be used by all healthcare professionals in principle.

Tele-care can be practiced by pharmacists or paramedics, as well as other professionals listed by Decree (e.g., nurses, audioprosthetists, dieticians, medical laboratory technicians).

All such professionals must comply with the normative provisions relating to the conditions of practice of their profession, whatever their speciality or mode of practice (private, salaried or hospital).

Teleconsultation companies

The Social Security Financing Act for 2023 endorsed the adoption of a new accreditation regime applicable to teleconsultation companies in order to promote the coverage of the teleconsultation services they offer, under certain conditions:

• conditions of incorporation (e.g., specific approval, corporate purpose, company form),
• detention conditions (i.e., teleconsultation companies may not be under the control, in the sense of commercial law, of a natural or legal person exercising the activity of supplier, distributor or manufacturer of medicines, medical devices or medical devices, except for devices allowing the performance of a teleconsultation act);
• operational conditions (e.g., ensuring that their digital tools and services comply with the rules relating to the protection of personal data as well as the interoperability, security and ethical guidelines applicable to digital health services; proposing that teleconsultation procedures be performed by physicians they employ).

Information and communication technologies

Telehealth requires the use of information and communication technologies. Specific requirements apply depending on the type of telehealth service and device at stake.

In particular, the use of such technologies must be adapted to the clinical situations of patients and must guarantee the security of the data transmitted (confidentiality, protection of personal data), under conditions that comply with the interoperability frame of reference (from the CI-SIS) and security frame of reference (PGSSI-S) developed by ASIP Santé (Art. L. 1470-5 and L. 1470-6 of the FPHC).

The digital support used by healthcare professionals must also comply with the regulations relating to the hosting of health data in application of Article L. 1111-8 of the FPHC.

The Ministry of Health has further published a list of telehealth digital solutions with their safety scoring based on declarations made by solutions providers.

The scope of permitted applications of telehealth in Germany is very broad and there are no limitations to specific fields of medicine, dentistry or psychotherapy. Telemedicine can be an integral part of almost every medical specialty. Furthermore, since April 2022, there is now also the possibility of telemonitoring of patients suffering from certain forms of cardiac insufficiencies: the patient’s medical data are regulatory transmitted to a telemedical center where the data is clinically monitored and the attending physician of the patient is informed in case of any irregularities that require further clinical action.

Telehealth applications / technologies must be approved by the German Federal Office for Information Security ("BSI") and / or the Society of Telematics ("gematik"). Telehealth applications / technologies that are currently authorised in Germany include, inter alia, online audio-video appointments, remote diagnostics and monitoring (e.g. patients with cardiac resynchronisation therapy (CRT), implants or implantable cardioverter defibrillators (ICD)) and online video conferences for case-related discussions (e.g. conciliar discussions of X-rays, CT scans & MRI’s) from various providers. In contrast to that, commonly used videoconferencing / teleconferencing apps and platforms like Skype, Zoom, etc. are not approved for telehealth services in Germany. In addition, the German Federal Framework Agreement for Physicians ("BMV-Ä"), inter alia, stipulates further requirements of the technical procedures for the provision for certain telemedicine services by physicians accredited by the Statutory Health Insurers ("SHI" – "GKV"), for example, video consultations (cf. BMV-Ä, Annex 31b).

Telehealth services are provided in Greece by the National Telehealth Network ("EDIT"), which initiated its full operation at the onset of year 2016 with the mission to provide health services to the inhabitants of the remote Aegean islands and to overcome any constraints arising out of the geographical particularities of the place of residence.

To date, 270 health professionals have been certified by EDIT, out of which 67 are doctors offering various types of healthcare services, including psychiatry, surgery, general pathology, dermatology, cardiology, ophthalmology, urology, dentistry, endocrinology, and orthopaedics.

EDIT offers: (1) specially designed areas for exclusive use and controlled access; (2) a video conferencing system (high definition camera and a screen of high quality); (3) a special telehealth platform; (4) certain medical tools that are connected to the platform, so that the results of the medical examination conducted by the doctor are displayed in real time; (5) tele-appointment monitoring; and (6) patient file recording.

There are various types of healthcare services for which telehealth is available, including general practice, psychiatry, dermatology, dentistry, geriatrics, and occupational and physiotherapy services. Almost all types of healthcare services utilise telehealth through the "HA Go" app provided by the Hospital Authority ("HA"), a statutory body managing government hospitals and institutions in Hong Kong (see Costs of Telehealth for further details). Such healthcare services are made available to the public through the use of existing messenger and teleconferencing apps (e.g. WeChat and Zoom), as well as proprietary platforms and apps.

Telemedicine may be provided in the healthcare service activities as listed below

• patient management in the form of teleconsultation, which is the basis for teleconsultation with a specialist,
• the reception of declarations of information, consent and data processing from patients,
• pre-screening in the form of a teleconsultation to assess the need for care and the seriousness of the health condition, based on a personal encounter,
• pre-contact and data collection to make face-to-face care following teleconsultation faster and more efficient,
• diagnosis and therapeutic recommendations by means of teleconsultation, remote monitoring and remote diagnostic tools,
• prescription of medicines,
• follow-up and after-care after a previous face-to-face encounter,
• organizing teleconsultation,
• issuing referrals,
• psychotherapy, crisis intervention, parental counselling, counselling, supportive psychotherapy,
• physiotherapy by means of teleconsultation,
• breastfeeding counselling,
• nurse care services and
• advice and counselling by telephone, online or in other forms.

In case the telehealth service is provided online, the healthcare service provider must also ensure there is proper broadband internet access, proper and stable data transmission, and data security and malware protection. Further, the unequivocal identification of the patient is the responsibility of the provider.

The healthcare service provider shall offer to the patient telemedicine services through video technology for facial identification if the treatment would not be feasible through other telemedicine services due to the protection of the patient’s data, examination of certain symptoms of the patient or the nature of the treatment. In such a a case, identifying the patient is mandatory prior to providing healthcare services.

There is no specific limit on which services might be provided by way of telehealth and therefore various disciplines may provide these services, including general practice and hospital consultations. The use of telehealth is determined by the hospital or clinic providing the healthcare services, and may be determined by the facilities of the provider, their assessment of the risk and suitably of service, or other relevant factors, and the scope of services currently available in Ireland extends to general practice. This is decided by the providers on a local level and determined by the providers based on the risk profile, facilities and other relevant factors.

In respect of the platforms used to provide these services, the National COVID-19 Telehealth Steering Committee has approved the following solutions, made available during the COVID-19 pandemic, to support communication across the health service:

• Attend anywhere;
• Microsoft Teams;
• Skype for Business;
• WhatsApp (on an exceptional basis); and
• Cisco WebEx.

While this guidance issued by the HSE is in response to the COVID-19 pandemic, it is not time-limited and the guidance anticipates that providers may already have telehealth services in place. However, the guidance may in any event provide useful information to those implementing telehealth services. We recommend that HSE guidance should be monitored for changes.

Where telehealth services are provided independently, a variety of platforms and technological options are deployed in order to these services.

Telehealth services normally include the following subjects:

• Patients;
• One or more "Provider(s)" (Centro erogatore) – Public or private HCOs and HCPs providing telehealth services;
• A "Services Centre" (Centro Servizi) – To manage the data exchanged between patients and providers. Please note that a "Provider" may also carry out the functions of a "Services Centre".

Telehealth services may cover several areas of human medicine (e.g. cardiology, psychiatry, and paediatrics). In particular, telehealth services may play a pivotal role in laboratory and diagnostic imaging.

The MoH Guidelines consider that telehealth services may specifically apply to:

• Secondary prevention – Telehealth services for people who are classified as being at risk or who have already been diagnosed (e.g. diabetes or cardiovascular diseases);
• Diagnosis – Telehealth services may support the diagnostic process (e.g. by facilitating the performance of specific laboratory tests);
• Treatment – Telehealth services aimed at making therapeutic choices;
• Rehabilitation – Telehealth services for specific categories of patients (e.g. frail patients); and
• Monitoring – Telehealth services may help connect patients with their treating physicians / caregivers in order to properly monitor disease management.

Telemedicine Services shall consist of the following services:

1. Tele-radiology;
2. Tele-electrocardiography;
3. Tele-ultrasonography;
4. Teleconsultation clinic (a long distance clinical consultancy service to assist in helping diagnosis and / or providing opinion / suggestion on clinical governance). This service may be conducted in writing, voice, and / or video and shall be recorded in a medical record in accordance with the prevailing laws and regulations.

All types of telehealth service, including dentistry, are generally available in Japan. Telehealth services are provided by videoconferencing / teleconferencing apps as specified by the relevant medical institutions. Remote medication instructions and electronic prescription systems are becoming more widespread.

The Kenya Medical Practitioners and Dentists Council (“KMPDC”) has previously issued provisional approvals for various registered and licensed health institutions to offer virtual medical services. These approvals granted permission to the health facilities to offer virtual consultation health services and are subject to review every three months from date of issue.

Executive Regulations are currently awaited which are expected to list out the services can be offered through teleconferencing.

The hospitals currently offer certain consultancy services through general videoconferencing and teleconferencing apps such as Skype and Zoom.

The eConsult platform is open to all physicians regardless of their specialty and mode of practice (liberal, salaried or in a hospital), but also to dentists and midwives. This consultation takes place either via audio or video. While teleconsultation is encouraged in the current health crisis relating to COVID-19, it is up to the health professionals to decide whether to use it. Thus, the use of the eConsult platform for teleconsultation is not mandatory. The above-mentioned health professionals are also free to use other methods such as telephone or video call applications such as Skype or Zoom.

While the above mentioned guidelines do not apply to psychologists (but only to physicians, dentists and midwives), psychologists and other health professionals are free to use teleconsultation if they wish to. With regard to psychologists, a free telephone psychological support service has been open during the pandemic in order to help people in distress. This teleconsultation is free of charge and offers multilingual psychological support, seven days a week, from 7 am to 11 pm.

Telehealth is currently available for any type of healthcare services as long as it complies with the regulatory framework applicable for healthcare services generally and, if necessary, with the regulatory framework applicable to each specific sector and / or activity within the field of healthcare.

Mexican laws do no establish any kind of requirement or set forth any indication regarding the platforms that must be used when providing telehealth services. However, NOM-024-SSA3-2012 (discussed below) regulates the exchange of information between electronic health record information systems ("SIRES"), which is an information system that allows the capture, management and exchange of structured and integrated information from the patient’s clinical record, as well as geographic, social, financial, infrastructure and any other information that documents medical care. SIRES must obtain a certification under NOM-024-SSA3-2012.

Part of telehealth services currently being provided in Morocco involve the use of proprietary technology or platforms. The telehealth services includes remote medical consultation, pharmaceutical prescriptions and psychological counselling.

Telehealth is relatively new in Namibia.  Before the Covid-19 pandemic in 2020, telehealth received very little attention.  One of the consequences of the pandemic is that more attention is being paid to the possibilities of telehealth to provide increased access to health services.  The Namibian Broadband Policy – already before the pandemic – recognized the importance of access to broadband for the provision of telehealth services. 

In 2016, Namibia became a participant of the US telemedicine and video conferencing program called Extension for Community Healthcare Outcomes (or Project ECHO) which provides training to healthcare workers who deal with HIV patients.

There is a plethora of applications of telehealth that is possible. The government itself provides the following examples:

• Geo tracking of mentally ill patients;
• Lifestyle monitoring;
• Teleconferencing consultations (for all kinds of fields such as general practitioners and dentists);
• Medication dispensers;
• E-mental health; and
• Social robotics.

Some functions require proprietary platforms tailored to the specific needs of the situation. For other more general consultations, general videoconferencing apps are used at the choice of the HCP, bearing in mind confidentiality restrictions.

The Dutch Government has introduced so-called “Health Deals”, which are cooperations between the government and third parties to innovate healthcare. This deal does not entail any funding by the government, but allows the government to share knowledge, help bringing parties together and ensure good partnerships.

There are no limitations to the scope of practice of telehealth services in Nigeria. It covers every field of telehealth services.

Telehealth is available for a range of healthcare services in New Zealand, including: general practice, optometry, dentistry, adult and women’s health, counselling, addiction support and other mental health services, palliative care reviews, fitting hearing aids, physiotherapy, and paediatrics.

In addition, the New Zealand government recently expanded the coverage of its 'e-Prescription' service to allow prescribers to provide electronic prescriptions for controlled drugs. The amendment of the Misuse of Drugs Regulations 1977 marks a continuance of the initial e-prescribing measure adopted by the government at the start of the pandemic to support the continuity of remote care.

In May 2022, the NZ Telehealth Forum published a white paper exploring the Patient Anywhere Specialist Everywhere (PASE) model in New Zealand.  The purpose of the paper is to explore how telehealth delivered in the PASE model can improve the delivery of healthcare in New Zealand, and reduce inequities based on limited services offered in certain regions.  Feedback is currently being sought.

In terms of proprietary technology and platforms, there are 4 areas within the broader telehealth space that are being used in New Zealand:

• telemedicine (the use of telecommunication and IT to provide clinical healthcare at a distance via video conferencing, and store and forward);

• telemonitoring (remotely collecting and sending patient data so that it can be interpreted and then contribute to the patient’s ongoing management);

• mHealth (mobile health – the use of mobile communications technologies in medical and public health practice, including the delivery of health information, health services and healthy lifestyle support programmes. mHealth can be delivered by devices like smartphones and tablets); and

• health apps (for use both by clinicians and consumers.)

The technology used in the delivery of telehealth services in New Zealand varies.  Te Whatu Ora (Health New Zealand) has indicated a health app formulary will be established as one of the actions from the new Health Strategy.  The formulary will provide a list of health apps Te Whatu Ora considers may be used with confidence.

Telehealth is primarily used in general practice, by dermatologists and psychiatrists, and also by physical therapists and chiropractors, as well as in issuing prescriptions, with a variety of platforms.

The authorities have also created Helsenorge which is a public website for residents of Norway. It provides information on a variety of health-related issues, and persons can also log in to use digital health services. Helsenorge allows persons to actively participate in decision-making and monitoring of their own health including vaccinations, medical appointments, medicines, critical information, next of kin and so on. The content is provided by various contributors in the healthcare sector.

There is no specific fields. The telehealth available is an application developed by Ministry of Health called Shifa allows to all users have valid civil ID and registered Oman mobile number with health institutions, to view their own medical record and reports, appointment, prescriptions, lab investigations, immunization…ltc.

Also, the Ministry of Health has a platform called eHealth Portal provide services such as ask a doctor, chatting, appointment and reports.

All types of healthcare services may be rendered this way. Obviously, physician must act with due diligence and follow current state of medical knowledge – if telemedical service is not sufficient from the medical standpoint, then the standard visit should occur.

There are no general rules what tools (platforms, apps etc.) should be used while rendering telehealth services.

Telehealth is applicable to all medical areas (where possible) but the consultations that can be carried out depend on the healthcare professional's assessment of its appropriateness and on the technological capacity of the healthcare institutions of SNS. Health Regional   Authorities provide for the equipment needed to implement teleconsultations. There is no legal imposition in relation to the use of specific technological platforms, but in the scope of the SNS, teleconsultations are performed through a platform developed for such purposes (RSE Live).

PHCC and HMC have made available telehealth consultations for patients requiring both routine and primary care including a special telehealth system for delivering better outcomes for stroke patients and a telehealth system to deliver speech therapy. HMC’s urgent consultation services enable patients with non-life threatening conditions to speak to a specialist physician that will provide them advice, diagnosis and offer prescriptions. This service covers eleven specialities for urgent care needs for urology, cardiology, orthopaedics, general medicine, general surgery, dermatology, ENT, OBGYN, dental and paediatrics. HMC’s Department of Geriatrics has also launched a virtual clinic for patients enabling elderly patients to receive consultations in the comfort of their own home.

Call centres called Nesmaak at 16060 and Hayak at 107 are available for routine calls.  Patients can dial 160000 and choose the PHCC option, they are then routed to the a PHCC community call centre offering remote telephone and video consultations.  The community call centre operates 7 days a week from 7 am to 11 pm. Patients accessing this service can expect a video or telephone consultation with a physician.

The PHCC has launched a mobile application called Nar’aakom for individuals to access digitised services and for patients to book virtual consultations via the applications with the aim of accelerating digital transformation in the health space.

GEO no. 196/2020 covers prophylactic and curative telehealth services and regulates the following services: (i) remote consults, (ii) tele-expertise, (iii) teleassistance, (iv) teleradiology, (v) telepathology and (vi) remote monitoring of the patient.

The services can be performed by any means of telecommunication, irrespective of the audio or video platform, the electronic equipment, cable networks, optic fibre, radio, satellite or other such means that are used. The communication platforms that are used must ensure the security of the data.

The medical specialties and the list of services that can be performed through telehealth are regulated through GD no. 1133/2022..

Telehealth services are only available if they can be provided on a remote basis. By way of example, primary medical consultations, which include physical checkups of patients, establishing diagnoses, and prescribing medicines, can only be performed through an in-person appointment with a licensed clinic or healthcare professional. Although statutory amendments to extend the breadth of telehealth services (e.g., to include diagnosing medicial conditions and prescribing medicines) were considered, they were ultimately rejected.

Telehealth services are not limited to the same doctor or clinic which performed the initial consultation or examination. Neither the Health Protection Law or the Order provides explicit requirements for the patient to stay with the same doctor or clinic after the initial in-person consultation or examination. Therefore, a patient can start with one doctor or clinic and continue through telehealth services after that.

There are also some technical requirements for telehealth services in Russia. Telehealth services can only be performed with the use of state-approved IT systems which allow for precise identification and verification of both healthcare providers (clinics or healthcare professionals) and patients. Specifically, the unified system of identification and authentication ("ESIA") must be used.

ESIA is regulated by the Resolution of Russian Government No. 977 dated 28 November 2011. In brief, this is a state-run system that is used for official interaction between state officials, and / or between state officials and citizens, and ensures all users identification and authentication based on enhanced e-signature. Some industry participants have indicated that this system is somewhat bulky and inconvenient to use, especially by patients, which may impact the uptake of the use of telehealth services. In light of the above-mentioned licensing requirements, the limitations on the scope of services which can be provided, and the cumbersome technical requirements, telehealth services are performed in limited scope in Russia.

The Telemedicine Regulations define telemedicine as "a remote medical practice using information and communication technology", which should be utilised either as an interaction between a patient and a healthcare practitioner ("HCP") or between two or more HCPs. The interaction shall take place between two different sites and may involve robots or artificial intelligence.

Telemedicine is available for screening, triage, consultation, diagnostics, obtaining a medical opinion from an HCP, treatment support, and the monitoring of medical conditions. Teleconsultations can either be between a patient and a HCP or between two or more HCPs and must involve a video consultation (teleconsultations cannot be solely audio) but need not be synchronous.

Telemedicine may be practiced by any KSA accredited HCP within either the public or private sector. Telemedicine undertaken by an HCP outside KSA must be undertaken under the supervision of a KSA based HCP. All legal requirements and protocols that are applied to an HCP in physical practice in KSA apply equally to the practice of telemedicine.

There is no specific field of healthcare in relation to which telehealth services are provided. However, in terms of the Guidelines, there are three types of telehealth: namely:

1. Routine telehealth
   This is described as being patient-initiated or used by practitioners to obtain a second opinion from other practitioners and should be practiced in circumstances where there is an already established practitioner-patient relationship or, where such a pre-existing relationship does not exist, telehealth consultations may take place provided it is done in the best interest of patients. This practice is only used as an adjunct to normal medical practice, and only replaces 'face-to-face'  services where the quality and safety of patient care is not compromised, and the best available resources are used in securing and transmitting patient information. However, this is not necessarily the case in South African practice.
2. Specialist telehealth
   In terms of the Guidelines, specialist telehealth consultations form the bulk of telehealth practice in South Africa, particularly in rural areas as a result of human resource capacity challenges.
3. Emergency telehealth
   According to the Guidelines, emergency telehealth involves judgements by healthcare practitioners based on sub-optimal patient information. In emergencies, the health and well being of patients are the determining factor with regard to stabilizing patients and having them referred for medical care. Any emergency instructions must be in writing and appropriate to the services rendered via the telehealth platforms in these circumstances.

Many South African health insurers use technology platforms to connect their clients with healthcare professionals via text, call or video call. The consultation with the healthcare professional is also done via electronic means.

While there are generally no limits in terms of the types of healthcare services which can be provided by way of telehealth in Singapore, doctors are required to adhere to the applicable guidelines and regulations in providing such services. Generally, the diagnosis, prescription of medicine and issuance of medical certificates via telemedicine (i.e. without a physical medical consultation) would be subject to the professional judgement of the relevant doctor and the specific facts and circumstances of each presenting case. Specific telemedicine applications may also have recommendations on the type of healthcare services or ailments that telemedicine under the application should be used for. In particular, the scope of ‘medical services’ which can be provided remotely under the proposed new regime under the HCSA remains broad. ‘Medical services’ under the proposed new regime is proposed to mean:

1. (i) a service that is provided, or an act that is done, by a medical practitioner in the course of his or her practice as a medical practitioner; and (ii) any ancillary service;
2. prescribed specified service; but
3. excludes (i) the provision of accommodation to any patient for a period exceeding 12 hours; (ii) the administration of general anaesthesia; and (iii) the conduct of any surgical procedure other than minor surgical procedure.

For completeness, telehealth in Singapore is provided to the public by way of both telemedicine applications, as well as videoconferencing and teleconferencing applications. In particular, we highlight that the Infocomm Media Development Authority, Enterprise Singapore and the Ministry of Health ("MOH") had announced in May 2020 ("Announcement"), an expansion of pre-approved teleconsultation (video) solutions to help Small and Medium-sized Enterprises ("SMEs") in, inter alia, the healthcare sector, to manage the impact of the COVID-19 pandemic.

It was also stated in the Announcement that video was the preferred mode of telemedicine, and it allows doctors to assess key visual cues and have a more natural consultation with patients.

Telehealth, as permitted during COVID-19 includes all healthcare services, such as general practice, psychology, and dentistry. Though it is currently quite common to provide consultations by telephone or e-mail (or via other electronic communications), such consultations are not explicitly supported by Slovak legislation (e.g. verification of results by telephone, and health consultations) and general video conferencing and teleconferencing apps like Skype and Zoom are not allowed to be used.

A harmonized health information system (eVEM/eZdravje) at national level. The eVEM/eZdravje system provides various health information services within Slovenian public health system and consists of:

• online prescription service"eRecept" (ePrescription);
• online doctor´s appointment booking portal: "eNaročanje" (eBooking);
• the "ePosvet" option (eCounseling) which is electronic communication between healthcare workers, family medicine physicians, and doctor specialists for the purpose of sharing opinions on clinical questions;
• Online Central Patient Data Register (in Slovene: Centralni register podatkov o pacientih) with regard to patients that temporarily and permanently reside in Slovenia, pursuant to Article 14.b ZZPPZ. The purpose of the Central Patient Data Register is to enable electronic exchange of health data between healthcare providers, with the goal of making patient data easily accessible to all who treat them;
• patient-facing zVEM platform which serves as the access point to the above functions (available also as a mobile application);
• healthcare providers-facing zVEMPlus platform for collection of data;
• Telekap (Telestroke), a video conferencing system and a web-based diagnostic support application that operates through audio-video conferencing for patient examinations and is used in 12 hospitals throughout Slovenia. The users of the Telekap information solution are specialist doctors, physicians, and other healthcare professionals;
• numerous COVID-19-related functions including, but not limited, platforms for vaccination appointment scheduling and digital COVID-19 certificates; and
• several other platforms that enable communication between different entities pertaining to radiological data, injury-related information (for the purposes of police investigations), and the like.

Apart from that, there are also several private sector telehealth services available on the Slovenian market.

In general terms the fields of healthcare in which telehealth services are available in Spain include remote medical assistance (remote patient monitoring and second opinion) in medical specialties as psychology, dermatology, pediatrics, gynecology, oncology, dentistry, allergology, cardiology, ophthalmology, laboratories, and radiology. These services are in most of the cases offered by health insurance companies which use their own proprietary platforms (these platforms are developed by third parties, being the insurance companies or licensees).

Telehealth in the form of digital healthcare visits is mainly provided within primary care and psychology as well as for veterinary care. In general, such services are provided through the use of proprietary platforms.

The use of telemedicine has been increasing rapidly especially during the COVID-19 pandemic and is available for various healthcare services, such as general practice, psychology and ophthalmology. The general practice we have seen in the market is the provision of healthcare services via videoconferencing applications such as facetime, LINE or in-app chat / messenger.

There have been telemedicine services already provided in various cases in Thailand, e.g.:

• for diabetes patients in Pattani Province, the Southern part of Thailand;
• online services provided by various hospitals; and
• applications provided by licensed private hospitals and other platform providers.

Currently, the use of telemedicine has been restricted to the provision of medical knowledge for treatment and not as a platform for a sale of drugs / medicines. This is to avoid the wrongful advertisement or prescription of dangerous or specially controlled drugs (e.g. drugs for mental health) to the public without proper diagnosis by, and consultation with, the medical practitioner / pharmacist.

There are a range of telehealth services currently being provided in the UAE.

Those offered by the UAE government are listed in Costs of Telehealth.

We aren’t aware of the extent to which general videoconferencing applications are being utilised for medical consultation or dentistry services, if at all. However, we note that for psychiatric support a number of smaller providers appear to be offering such services.

The type of healthcare services for which telehealth is currently available in the UK includes the following:

• General practice – Doctors have been providing remote video and telephone consultations to patients.
• Pharmaceutical – prescriptions can be ordered via an app.
• Dentistry – During the COVID-19 pandemic, many dentists were providing dental care services remotely. There are also a number of companies on the market in the UK which provide clear aligner therapy remotely.
• Psychological – telephone and video counselling has been provided to patients.

Generally speaking, telehealth can typically be used in some form for a wide variety of professional practices, including medicine, dentistry, psychology and other mental health services, etc., however, the scope of permissible telehealth practice will be governed by state law as well as the specific regulations and guidance adopted by each state’s professional licensing boards.

To the extent that state law and the applicable licensing boards are silent on the practice of telehealth by a particular licensed discipline (which may still be the case for non-medical disciplines such as dentistry), the practice is generally viewed as permissible; however, caution should still be exercised and proper due diligence conducted to ascertain whether the particular licensing body has issued any disciplinary actions against a licensee for the practice of telehealth and also whether any professional trade association has released guidance or standards of practice for the particular discipline. For instance, a state may be silent on the practice of teledentistry, but the American Dental Association has released a policy on teledental practice. During the PHE, some state licensing bodies issued temporary guidance and waivers for telehealth practice, including waiving in-state licensure requirements if a provider had an out-of-state license, or issuing emergency licenses to healthcare providers licensed in other states, along with the ability to practice across state lines via telehealth. While certain states have sunset some of these flexibilities, telehealth and corresponding regulations will continue evolving as the digital health sector continues to grow.

While telehealth does not require the use of proprietary technology or platforms, to the extent the provider of telehealth is a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), then HIPAA would require that the platform be secure and be used in accordance with the HIPAA Privacy and Security Rules. If a health care provider engages in billing insurance for its services, then it will likely be a “covered entity” under HIPAA and if a technology platform supports those types of health care providers the platform vendor will likely be a “business associate” under HIPAA. This means that if a covered entity or business associate uses a third-party platform (e.g., Zoom) to provide telehealth services, it will need to enter into a business associate agreement with such third-party platform.  Many telehealth offerings in the U.S. are also beginning to incorporate certain technologies into their platforms, such as clinical decision support tools and remote patient monitoring. These additional functionalities are subject to further regulation, including by the Food and Drug Administration (FDA) and state law, and may have technical coverage requirements if reimbursement will be sought for such expanded functionalities.

Telehealth services are generally available for consultation, appointment and high level medical advisory services. There are no proprietary technology platforms launched specifically for the provision of telehealth services. The absence of such technology may serve as a reason why the Government has not developed such targeted telehealth regulations. The COVID-19 pandemic has resulted in a proliferation in the use of communication apps on mobile phones as exchange services for the payment of medical services, and the use of apps such as WhatsApp for general consultations and to facilitate medical appointments. Furthermore, the Government, through the Ministry of Health, has launched hotlines which the public can use for both emergency and basic health consultations.

There are telehealth offerings currently available in the private health system, for example Maternity Health using Facebook Messenger and General Practitioner Doctor Consultations through Dial-A-Doctor, which uses WhatsApp calls and direct calls to consult with specific Doctors. Private medical aid institutions also offer online consultations with various healthcare professionals using applications such as Teams and Zoom.