Telehealth only services

1. RACGP Position

• Telehealth is not a substitute for routine in person care. Telehealth consultations between patients and providers unknown to each other should be limited to specific, clinically justified circumstances.
• Telehealth should complement comprehensive, whole‑person, GP‑led care and be used within ongoing clinical relationships wherever possible.
• Asynchronous care provided by GPs where there is an existing clinical relationship with the patient is acceptable.
• Prescribing must be based on a real‑time consultation (in‑person, video or telephone); asynchronous, questionnaire‑only models are unsafe and not supported.
• Telehealth only providers should actively promote continuity of care by encouraging patients to develop relationships with a usual GP or practice and seek consent to routinely and securely share consultation summaries with the patient’s usual GP/practice.
• Clinicians providing telehealth‑only services must hold appropriate qualifications, Ahpra registration, and professional indemnity insurance that covers telehealth with unknown patients.
• Telehealth only services must have strong clinical governance, risk management, audit and quality improvement systems, and be free from conflicts of interest including inducements for products or services.
• Technology used for telehealth consultations must meet Australian privacy law requirements and support secure, interoperable information exchange.
• Regulation should be strengthened to protect patient safety and prevent excessive and inappropriate prescribing, predatory marketing practices that target at risk populations and fragmentation of care.

2. Definition

2.1 What are telehealth only services?

Telehealth refers to services provided via telephone, video and/or electronic message by a health professional. Telehealth services can be:

• synchronous – these services take place in real time, and can be conducted in-person, via video or telephone
• asynchronous – these services do not take place in real time – the patient and practitioner communicate in their own time, with delays between contact (for example, text messaging services)

Telehealth only services do not offer in-person care and are typically offered to patients through online platforms (e.g. websites or apps), and the providers have no pre-existing relationship with, or prior knowledge of, the patient.

These services often operate on a transactional and product specific model, offering targeted treatment pathways for a particular issue, condition or medicine. For example, some offer specific services such as weight loss advice and medicines, access to specific treatments such as medicinal cannabis, or a service like a repeat prescription or a sick certificate.

Some telehealth only services offer a broader array of services, such as those provided by health insurers to their members and there are government supported services such as Healthdirect and various Virtual EDs around the country.

Asynchronous consults models are being utilised by some telehealth only providers (despite the release of the Medical Board’s guidelines for telehealth consultations with patients, which do not support prescribing or providing healthcare without a synchronous consultation).

Most telehealth only services are not eligible for Medicare benefits.

2.2 General practice healthcare vs. telehealth only services

Many, or most, GPs and general practices offer synchronous telehealth care to their patients in addition to in person care. The following table outlines broad differences between the healthcare provided by general practice and the type of service offered by telehealth only services.

	General practice	Telehealth only services
Provides telehealth services	✔	✔
Whole person care	✔ Manages the full spectrum of a patient’s physical, mental and social health needs.	✘ Typically focused on a product or specific service (e.g., weight loss, sexual health concerns, requests for medicinal cannabis or sick certificates).
Continuity and coordination	✔ The GP-patient relationship is built over time, allowing for more personalised and effective care.	✘ Episodic services usually provided without coordination with other members of the patient’s healthcare team.
Team-based care	✔ As the centre of the broader healthcare ecosystem, general practice involves collaboration with nurses, allied health professionals, and other specialists.	✘ Services typically operate outside of team care networks and don’t connect with the patient’s usual GP or broader health system.
Preventive care and chronic disease management	✔ Prioritises comprehensive, ongoing care that requires regular monitoring, examinations and in-depth assessments.	✘ Product-specific telehealth consults are not focused on preventive health or chronic condition management.
Quality care	✔ Requires in-person consultations complemented by telehealth delivered by the patient’s usual GP or care team. Supported by comprehensive clinical assessments and governance standards.	✘ No in-person physical relationship. Often relies on online questionnaires and lacks formalised standards and accreditation.

3. Background

The RACGP has significant concerns about the recent growth in telehealth only services which are providing access to targeted treatment pathways for specific issues, conditions or products. These services can undermine the therapeutic relationship between a patient and their usual GP, fragment care, and put patient safety at risk.

The RACGP recognises patients may wish to use telehealth only services to gain access to services not offered by their usual GP or general practice. The Requirements outlined in section 4 below should be adopted by telehealth only providers and medical professionals working in these services to ensure consumers using telehealth only services receive safe care that is appropriate and complements, rather than undermines and potentially conflicts with, the comprehensive healthcare provided by specialist general practice. The Requirements outlined in section 4 below should be adopted by telehealth only providers and medical professionals working in these services to ensure consumers using telehealth only services receive safe care that is appropriate and complements, rather than undermines and potentially conflicts with, the comprehensive healthcare provided by specialist general practice.

4. Requirements for telehealth only services

1. Prioritise the consumer’s usual GP or general practice

The limitations of the telehealth only service offering should be made clear to the consumer. Consumers must be advised they are not receiving holistic or comprehensive healthcare and to see a specialist GP for this.

Consumers who do not have a usual GP should be encouraged to develop an ongoing relationship with a local GP or general practice.

2. Share information with the consumer’s usual GP or general practice

Telehealth only services should ensure consumer consent is provided so a summary of the consultation can be shared with the consumers usual GP or general practice if they have one., Consumers should be advised that having a usual GP or general practice as the co-ordinator of their care, and sharing information prevents fragmentation of care and contributes to better outcomes.

The consultation summary and outcomes should be shared with the usual GP or general practice using secure digital communication. If a consumer can’t name their usual GP or general practice, the telehealth provider should attempt to identify a usual GP by searching in the consumer’s My Health Record for MyMedicare registration, a Shared Health Summary and/or the list of Medicare claims for GP consultations. The telehealth provider should document the results of these searches.

A summary of the consultation should also be uploaded as an Event Summary to My Health Record (where the patient has one).

3. An appropriately qualified, trained and legally indemnified workforce

Telehealth only services must ensure services are provided by health professionals with appropriate qualifications and training.

Consumers should be informed about the qualifications of the doctor or other health professional providing the service, including Ahpra registration status (such as whether the doctor has only general registration with Ahpra or is a qualified specialist general practitioner or other medical specialist) or a nurse practitioner or pharmacist.

All doctors and other health professionals providing telehealth only services must have professional indemnity insurance that covers for telehealth consultations with unknown consumers.

All health professionals delivering telehealth only services should be provided with additional training in:

• effective digital communication
• remote clinical assessments
• identifying limitations of telehealth
• privacy and security standards
• deciding when to recommend in-person care
• referral back to the patient’s usual GP or general practice, and
• access and use of My Health Record.

4. Synchronous prescribing

Telehealth only services must ensure prescribing is synchronous and does not take place without a real-time direct consultation, whether in-person, via video or telephone.

Asynchronous requests for medicines communicated by text, email, live-chat, online or are based on the consumer completing a health questionnaire are unsafe outside of an existing and in person therapeutic relationship.

5. Clinical governance systems

Systems must be in place demonstrating a robust approach to clinical governance. This includes:

• prioritising clinical safety
• transparent processes for reporting incidents, errors and near misses
• evidence based clinical decision making to ensure consistent and high-quality care
• clinical audits to identify areas for improvement
• risk identification and management to assess and mitigate potential risks and their impacts
• all documentation and consumer communications containing clinical information is reviewed and assessed by a qualified medical practitioner
• staff competency assessments to ensure clinicians have the qualifications, skills and knowledge to provide safe and effective care
• using data to monitor performance and inform decision making
• feedback systems to gather insights and improve or change services.
• effective communications systems to ensure data is shared with all relevant stakeholders.

6. Free from conflict of interest

Health professionals practising in telehealth only services must not be offered inducements or rewards for advising or prescribing products or services. The Medical Board Code of conduct for doctors is clear on this for good reason. Conflicts of interest are an inherent risk to high quality care.

7. Recording consultations only when necessary and with consent

Telehealth consultations should be audio or video recorded only if clinically necessary, and only with written consent from all participants in the consultation. Recording consultations raises potential legal and ethical concerns specifically related to privacy and data security. The considerations are the same as for the recording of in-person consultations. In the case of using AI Scribes, consent must be obtained for each and every consultation.

8. Maintaining high quality technology infrastructure and data security

Services must operate with reliable hardware, software and a stable internet connection. Any software and hardware used to deliver telehealth must meet Australian privacy legislation requitements to safeguard private and confidential information.

Both consumers and providers must have access to systems that support clear communication.

5. GPs working in telehealth only services

GPs working in telehealth only services, particularly those focused on single treatments or medicines, must ensure the care they provide isn’t compromised by commercial gain or convenience. As advised by the Medical Board guidelines for telehealth consultations, (the Guidelines) healthcare provided through telehealth is the practitioner’s responsibility and not the employer’s.

The Guidelines establish a range of requirements for telehealth consultations. These include:

• confirming the identity of the consumer
• applying the usual principles for obtaining consumer consent
• a private environment to discuss health issues openly
• ensuring the consultation is culturally safe, maintains professional boundaries, is clinically appropriate and where possible, meets the same standards of care as provided in a face-to-face consultation
• assessing the appropriateness of using telehealth and making arrangements for the consumer to have a face-to-face consultation if necessary
• undertaking a clinical assessment of the consumer which includes a comprehensive medical history, gathering information from other sources such as My Health Record, actively listening to the consumer concerns, establishing a diagnosis and management plan and demonstrating appropriate behaviour and respect for the consumer
• awareness of and compliance with state, territory and jurisdictional legislative requirements when prescribing medicines, including real-time prescription monitoring (RTPM) and/or My Health Record. This includes in the jurisdictions of both the prescriber and consumer.

Under the Ahpra's Shared Code of Conduct telehealth consultations must meet the same professional, ethical and clinical standards as face-to-face care. The RACGP’s Telehealth and supervision: A guide for GPs in training and their supervisors advises that telehealth consultations provided by GPs in training require supervision that is commensurate with normal supervision requirements. 

GPs must comply with privacy legislation such as the Privacy Act 1988 and the Australian Privacy Principles when collecting, storing and disclosing patient information.

6. The role of regulators in responding to concerns about safety and quality

One of the key regulatory challenges is that these services usually operate outside of Medicare, restricting regulator access to the existing mechanisms to monitor and respond to quality and safety concerns. In addition to these principles the RACGP believes greater regulation of telehealth only services is required.

The National Medicines Record, which will require online telehealth providers to upload all medicines related information to a patient’s My Health Record is a step towards greater regulation of prescribing by telehealth only providers and improving patient safety.

Ongoing regulation requires collaboration between various agencies, including Ahpra, the Therapeutic Good Administration (TGA), Australian Competition & Consumer Commission and state and territory health departments to ensure consumers are protected from harm. To support these agencies in their efforts the RACGP recommends:

• the TGA shares prescribing data from its Special Access Scheme with regulators when concerns are raised
• Ahpra takes quick and firm action against medical professionals in breach of their code of conduct, in particular where it relates to conflict of interest and providing unsafe care.
• increased financial penalties for breaches of advertising and promotion guidelines, in particular, where predatory marketing tactics target at risk populations. Current fines are too small to act as an effective deterrent
• regulators deliver consumer education focusing on what quality and safety elements need to be considered when using telehealth only services
• the Commonwealth considers how to ensure the separation of dispensing from prescribing, and mandates face to face prescribing for certain medications
• The ACCC should quickly identify and deal with false advertising claims, misleading or deceptive conduct and anticompetitive pricing or abuse of market power.

7. Conclusion

Continuity of care is essential to ensure high-quality and safe care for patients and to prevent fragmentation across the healthcare system. The requirements outlined here should be adopted by telehealth only providers and medical professionals working in these services to ensure consumers using telehealth only services receive safe care that is appropriate and complements, rather than undermines and potentially conflicts with, the comprehensive healthcare provided by specialist general practice.

Author: Practice Technology and Management
Contact: practicemanagement@racgp.org.au
Published: May 2026
Review date: 2029