Eucalyptus has used the Informa Connect Virtual Care conference to push for an industry self-accreditation model for the online telehealth sector.
Online telehealth in Australia needs to move towards an industry self-accreditation model, Eucalyptus’ senior legal counsel and head of public policy Lyndon Goddard has said at the Informa Connect Virtual Care conference in Sydney.
He was speaking to delegates about how to implement national safety and quality standards for telehealth.
“[Self-accreditation] strikes the balance of speed of implementation, while also maintaining a facility for some kind of enforcement,” he said.
He highlighted that while telehealth clinicians are regulated by AHPRA, the medicines they prescribe are regulated by the TGA, but the clinical systems within which they operate aren’t subject to a dedicated, unified regime.
Not only that, but existing standards, such as the National Safety and Quality Health Service Standards, are a poor fit for online telehealth.
Mr Goddard explained why:
“The first one is irrelevant criteria,” he said.
“Anyone who’s been through the NSQHS accreditation process will know that there are various expectations relating to blood management, infection risk, fall risk, etc, all very reasonable expectations in a physical hospital setting, but not really applicable in an online-only telehealth setting.
“The second problem is that there is an absence of relevant criteria that respond specifically to issues that apply to the telehealth sector.
“So how do you correctly identify patients who are seeking treatment online? How do you properly audit the safety and quality of consultations online? How do you manage the risks of inappropriate access to telehealth? What level of data security protection should you be providing in an online telehealth setting?
“Those are all things that are largely not covered in these other documents because they weren’t intended to,” he said.
Eucalyptus was one of the partners involved in developing the recent National Telehealth Standards which were launched earlier this month. However, questions have been raised about how to implement a document like that and how it can be enforced.
The standards include:
- Clinical evidence: identifying and monitoring clinical indicators and tracking incident rates and quality metrics.
- Safe and effective care: confirm that patients identity using appropriate evidence and supporting access to My Health Record to facilitate continuity of care.
- Partnering with patients: measure and analyse patient clinical outcomes against available clinical benchmarks.
- Clinician experience and independence: set minimum experience requirements for clinicians (PGY3+) and making sure their remuneration respects clinical autonomy and avoids conflicts of interest.
- Advertising and marketing practices: standards for advertising and marketing practices and having requirements for internal formal review processes
- Technology and data security: independent assurance such as ISO 27001 accreditation and strong access controls and broader data security protections
Mr Goddard outlined the four implementation models that could be considered.
The first is government regulation, similar to the NSQHS standards. This is how it works in the UK with the General Pharmaceutical Council and the Care Quality Commission.
“If you operate a telehealth clinic in the UK, you have to be registered with one of those two, or sometimes both regulators,” Mr Goddard explained.
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“That’s a really good system, but it obviously will take a long time and a lot of money to set up properly in Australia. Maybe time that we don’t have at the moment,” he suggested.
Another suggestion is government incentivising.
“So more of a carrot rather than stick approach,” said Mr Goddard.
This would be similar to GP clinic accreditation. It would take a reasonable time to implement but wouldn’t be enforceable.
The third suggestion was industry self-regulation which would take less time to set up than government regulation and could be similar to Medicines Australia.
“They can actually mete out fines to members that don’t meet the standards. So industry self-regulation is not necessarily a no-consequence model. It has some method of enforcement,” he said.
Finally, there is voluntary compliance which would take the least time to implement. However, similar to government incentivising, there wouldn’t be any consequences if companies didn’t comply.
“But it, at least, has some kind of moral benefit, and maybe a competitive benefit as well within the industry,” Mr Goddard admitted.
In Eucalyptus’s view, moving towards industry self-accreditation was the best next step.
“I appreciate that government regulation is another model, but I’m just concerned that it would take a very long time to put it into effect,” said Mr Goddard.
And time is of the essence particularly with so many Australians already using online telehealth.
“We’re talking about millions of consultations that are taking place every year in Australia. We’re talking about a very large volume of patients and consultations, and of course, all of those consultations ought to have rigorous expectations of safety quality attached to them.”
