Telemedicine Practice Guidelines for 2020 for Ayurveda, Siddha and Unani doctors from Telemedicine Society of India, Karnataka Chapter

1. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada MathAdapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Telemedicine Practice Guidelines
Enabling Ayurveda, Siddha and Unani Registered Medical
Practitioners to Provide Healthcare Using Telemedicine
Speaker
Dr Sanjay Sharma
Secretary TSI- Karnataka
Podiatric Surgeon
Moderator
Dr Prashanth Bhat
Member TSI- Karnataka
Telemedicine Society of India
Karnataka Chapter
Panelists
Dr Suresh Bada Math
President Elect TSI- Karnataka
Professor, Department of Psychiatry, NIMHANS
Dr Shivaram Varambally
Head of Integrative Medicine, NIMHANS

2. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Telemedicine Practice Guidelines 2020 for ASU - RMP

3. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Qualification: MD & DNB from NIMHANS, Bangalore., PGDMLE, PGDHRL and
PhD in Law from National Law School India University, Bangalore
Designation: Professor & Head of Telemedicine Centre, Head of Forensic
Psychiatry Services & Consultant, Community Psychiatry,
Affiliation: Department of Psychiatry,
National Institute of Mental Health and Neuro Sciences, (Institute of National
Importance), Bangalore – 560029
Visiting faculty: National Law School, Bangalore, State Human Rights Commission
and Karnataka Judicial Academy, Bangalore
Publications: 232 Published Scientific Articles in Indexed Journals and editor of three books
Awards: ‘Prof Raghuram’s-Distinguished Young Teacher Award and Dr.C.V.Raman Young Scientist Award, GOK
Positions: Member of the following committees instituted by the MoHFW,
Nirman Bhavan, New Delhi
a) Central Rules drafting committee for Mental Healthcare Act, 2017
b) Task force for Mental Health Care in Primary Health Centres

4. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Disclaimer
The discussions generated during the
presentation are academic only, they are not the
law themselves or not substitutes for
professional legal opinion.
For legal opinion please do contact advocate
Please do refer the original document of
Telemedicine Practice Guidelines
https://www.ccimindia.org/pdf/CCIM_Telemedicine_Guidelines_08-04-2020.pdf
https://www.mohfw.gov.in/pdf/Telemedicine.pdf

5. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
ASU - RMP Practice in India is Governed by
In India the practice of ASU medicine is mainly governed by
concerned state acts along with
• IMCC Act 1970;
• Practioner of Indian Medicine(Standards of Professional Conduct,
Etiquette, Code of Ethics) Regulations, 1982
• Drugs & Cosmetics Act 1940 & Rules 1945
• Clinical Establishment Act 2012.
• Information technology is governed by IT Act 2000, and the
• Information technology (reasonable security practices and procedure and
sensitive personal data or information) rules 2011

6. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Telemedicine Practice Guidelines -2020
• The guidelines are meant for ASU - RMPs under the IMCC act 1970
• These Guidelines have been prepared in partnership with NITI Aayog,
and adopted from the MCI (in Suppression by Board Of Governors) under
IMC Act 1956
• This guidelines constitutes Practioner of Indian Medicine(Standards of
Professional Conduct, Etiquette, Code of Ethics) Regulations, 1982

7. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Do this guidelines discusses
comprehensively about the
telemedicine setup in India?

8. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Specifically Explicitly Excludes
• Specifications for hardware or software, infrastructure building &
maintenance
• Data management systems involved; standards and interoperability
• Digital technology to conduct surgical or invasive procedures remotely
(prohibited)
• Other aspects of telehealth such as research and evaluation and
continuing education of healthcare workers
• Does not provide for consultations outside the jurisdiction of India
• Panchkarma procedures like Vaman, Virechan, Basti, Raktamoshan or
similar procedures in Siddha and Unani including cupping therapy

9. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Who can provide telemedicine
consultation?

10. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
ASU - Registered Medical Practitioner
‘ASU - RMP’ is defined as a person who is enrolled in the
State Medical Register of Indian Medicine or the Central
Register Indian Medicine under the IMCC act 1970.
A – Ayurveda Practioner
S – Siddha Practioner
U – Unani Practioner

11. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What are the prerequisite for ASU - RMP
to undertake teleconsultation?

12. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Prerequisite for ASU - RMP
Same Professional and Ethical norms/ standard as applicable to
traditional in-person consultation (real face-to-face)
Online courses will be made available mandatory online course
within 3yrs, qualifying courses will be prescribed interim period
follow the guidelines

13. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What are the ethical and legal standards for
telemedical consultation?

14. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Three Important Points to be kept in mind
• Same Professional and Ethical norms/ standard as
applicable to traditional in-person consultation (real
face-to-face)
• Same laws / rules as applicable to traditional in-person
consultation (real face-to-face)
• TELEMEDICINE PRACTICE GUIDELINES for
Ayurveda, Siddha and Unani Practitioners, April 2020

15. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can, I provide telemedicine
consultation to a patient residing
in another State?

16. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Inter State Tele Consult
ASU - RMP is entitled to provide telemedicine
consultation to patients from any part of India
Refer to the State Council Guidelines from where the patient is consulting from with respect to
prescription generation

17. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What are the Guiding principles of
teleconsultation?

18. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Guiding Principle for Telemedicine
Patient has the right to discontinue the teleconsultation
Telemedicine consultations will be treated the similar to
traditional in-person consultations with regard to ethics and law
The professional judgment of an ASU - RMP shall be the
guiding principle for all telemedicine consultation
The ASU - RMP can choose not to proceed
with the teleconsultation at any time/stage
ASU - RMP has the discretion to decide the mode
(in-person / text / audio / images/ video/ digital) of consultation

19. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can either of the party can be in an
anonymous mode during
teleconsultation ?

20. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Identification
• Telemedicine consultation is should not be anonymous: both
patient and the ASU - RMP need to know each other’s identity
• An ASU - RMP should verify and confirm patient’s identity
(registered ID, age proof)
• Every ASU - RMP shall display name and the registration
number in all his communication with patients

21. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What are the different methods/mode
of teleconsultation?

22. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Mode of telemedicine
• Text, Images, Audio, Video and Digital
data connected with devices
• Mixed method
• Any platform as per ASU - RMP’s
requirement / convenience
• Platform will be chosen by the ASU -
RMP
• No social media have been prohibited

23. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Who can initiate the
teleconsultation?

24. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Consultation Process
Patient to ASU - RMP
ASU - RMP to ASU – RMP
/ Specialist
Health Worker to ASU - RMP
Care Giver to ASU - RMP
First Consult / Follow-up Consult
ASU - RMP has the discretion to decide the mode
(in-person / text / audio / video)
of consultation

25. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What is the process of initiation
of the teleconsultation?

26. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Patient
Text/Audio/Video
Patient IdentificationConsent
Implied
Quickly Assess if
Emergency care is needed?
YES NO
Advice First Aid
Referral as appropriate
Detailed
Assessment / Investigation
Consent
Implied

27. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Detailed Evaluation
• Professional discretion to collate information
• Physical Examination in-person by an another ASU - RMP
• Ask for investigation and pause the teleconsultation
• If information is incomplete –ASU - RMP shall recommend in-
person consultation or repeat the tele consult with adequate
information
• ASU - RMP shall maintain all patient records

28. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
When should doctors take explicit consent?
What is the format of explicit consent?

29. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
An Explicit patient consent
• A Health worker, ASU - RMP or a Caregiver initiates a
Telemedicine consultation.
• An Explicit consent can be recorded in any form. Patient can
send an email, text or audio/video message.
• Patient can state his/her intent on phone/video to the ASU -
RMP (e.g. “Yes, I consent to avail consultation via
telemedicine” or any such communication in simple words).
The ASU - RMP must record this in his patient records

30. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What to do patient has called me, it
is an emergency consultation?

31. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Context
The ASU - RMP should exercise their
professional judgment
to decide whether a telemedicine consultation is
appropriate in a given situation or an in-person
consultation is needed in
the interest of the patient.

32. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Emergency Situation
The ASU - RMP, based on his/ her professional
discretion may
• Advise first aid
• Counseling
• Facilitate referral
In all cases of emergency, the patient MUST
be advised for an in-person interaction
with an ASU - RMP or RMP/ Specalist at the earliest

33. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What to do patient has initiated
teleconsultation for the first time?

34. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Type of Consultation
First Consult means - patient is consulting with the ASU - RMP
• for the first time; or
• earlier, but more than 6 months have lapsed since the previous
consultation; or
• earlier, but for a different health condition
• has consulted earlier, but the RMP does not recollect the same

35. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Patient
Text/Audio/Video
Patient Identification
Consent
Implied Quickly Assess if
Emergency care is needed?
YES NO
Advice First Aid
Referral as appropriate
Detailed
Assessment / Inv

36. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Management of first consultation
Health Education Counselling Medication
(Excluding Visha Dravya and
Narcotic and Psycotropic Substances)
First Consultation

37. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What to do my old patient has
initiated teleconsultation?

38. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Follow-up consultations
Follow-Up Consult(s) means - patient is consulting with the ASU -
RMP
• within 6 months of his/her previous in-person consultation
Excludes:
• new symptoms that are not in the spectrum of the same health
condition; and/or
• ASU - RMP does not recall the context of previous treatment
and advice

39. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Patient
Text/Audio/Video
Patient Identification
Consent
Implied Quickly Assess if
Emergency care is needed?
YES NO
Advice First Aid
Referral as appropriate
Detailed
Assessment / Inv

40. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Health
Education
Counselling Refill
Medication
Management of follow-up consultation
New
Complaint?
New
Consult
Follow-up Consultation

41. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can a care-giver initiate a
teleconsultation?

42. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Caregiver to ASU - RMP
• Caregiver is a family member or any person authorised by
the patient to represent
• Both present (Patient and Caregiver)
• Only caregiver is present
- Patient is minor
- Patient is incapacitated
- Formal authorization letter
- Verified by patient in a previous in-person consult with explicit consent
- Verified document to establish relationship

43. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can a Health Workers initiate a
teleconsultation with ASU - RMP?

44. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Health Worker initiating
• “Health worker” could be a Nurse, Allied Health Professional, Mid Level
Health Practitioner, ANM or any other health worker designated by an
appropriate authority
• Initiating setup :- any health establishment, health camps, home visits,
mobile medical units or any community-based interaction
• Can contact – public or private establishment
• HW - Should have seen the patient
• Informed Consent to be taken before initiating
• HW and ASU - RMP - Check ID/phone/address

45. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can a ASU - RMP initiate a
teleconsultation with another ASU – RMP
or an RMP / Specialist?

46. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
ASU - RMP to another ASU – RMP or RMP/ Specialist
• ASU - RMP can initiate teleconsultation with specialist or from
another ASU – RMP or RMP / Specialist.
• Such consultation can be initiated by a ASU - RMP on his/her
professional judgement
• ASU - RMP need to seek patient’s consent before proceeding
• Treating ASU - RMP shall be responsible for treatment and
other clinical responsibilities

47. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can a ASU - RMP prescribe any
medications on teleconsultation?

48. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Prescription Guidelines
• ASU - RMP has been empowered to prescribe medicine online
• It entails the same professional accountability as in the traditional in-person
consult.
• If a medical condition requires a particular protocol /SOPs need to be followed.
• ASU - RMP may prescribe medicines via telemedicine ONLY when ASU - RMP
is satisfied that he/ she has gathered adequate and relevant information about
the patient’s medical condition
• Prescribed medicines are in the best interest of the patient.
• ASU - RMP needs to follow the guidelines of prescription and should NOT
prescribe any Visha Dravyas and Narcotic and Psychotic Drugs
• Panchkarma procedures like Vaman, Virechan, Basti, Raktamoshan or similar
procedures in Siddha and Unani including cupping therapy are excluded in the
guideline

49. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Prescription Guidelines
• Tailor made formulations is a very old tradition in an ASU
system. Personal formulations of mixing some ingredients will
be allowed.
• It is mandatory for ASU RMP to disclose all the ingredients of
such formulations along with the preparation of the drugs.
• Manufacturing and right to prescribe medicine are governed by
State acts hence varies from state to state.
• The ASU RMP should always keep in mind this variation in
state act while prescribing the medicines, even though these
guidelines allow him to practice telemedicine all over India.

50. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Caution for prescription
“Prescribing Medicines without an appropriate
diagnosis/provisional diagnosis will amount to a
professional misconduct”
“Follow the teleconsultation guidelines”

51. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
How to send the prescription and
format of it?

52. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Issue a Prescription and Transmit
• As per the Practioner of Indian Medicine(Standards of Professional
Conduct, Etiquette, Code of Ethics) Regulations, 1982
• Photo, scan, digital copy of a signed prescription or e-Prescription to the
patient via email or any messaging platform
• ASU - RMP is transmitting the prescription directly to a pharmacy, he/ she
must ensure explicit consent of the patient that entitles him/her to get the
medicines dispensed from any pharmacy of his/ her choice
• The categories of medicines that can be prescribed via tele-consultation
will be as notified in consultation with the Central Government from time to
time.

53. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What constitute misconduct
during teleconsultation?

54. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Misconduct
• As per Practioner of Indian Medicine(Standards of Professional Conduct,
Etiquette, Code of Ethics) Regulations, 1982
– ASU - RMPs insisting on Telemedicine
– ASU - RMPs misusing patient images and data
– ASU - RMPs who use telemedicine to prescribe prohibited medicines
– ASU - RMPs are not permitted to solicit patients for telemedicine
through any advertisements or inducements
Penalties:
As per CCIM Act, ethics and other prevailing laws

55. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What records to be kept in
teleconsultation?

56. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
MAINTAIN DIGITAL TRAIL/ DOCUMENTATION OF CONSULTATION
Log or record of Telemedicine interaction (e.g. Phone logs, email records,
chat/ text record, video interaction logs etc.).
Patient records, reports, documents, images, diagnostics, data etc. (Digital
or non-Digital) utilized in the telemedicine consultation should be retained by
the ASU - RMP.
The ASU - RMP is required to maintain a copy of the prescription as medical
records as required for in-person consultations

57. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What about confidentiality and
privacy of data?

58. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
MEDICAL ETHICS, DATA PRIVACY & CONFIDENTIAILITY
• ASU - RMP shall abide by practitioner of Indian
Medicine(Standards of Professional Conduct, Etiquette, Code of
Ethics) Regulations, 1982 and with the relevant provisions of the
IT Act, Data protection and privacy laws or any applicable rules
notified from time to time for protecting patient privacy and
confidentiality
• The ASU - RMPs should ensure that reasonable degree of care
undertaken during hiring such services

59. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Can we charge fee for the
teleconsultation?

60. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Fee for Telemedicine Consultation
- should be treated the same way as in-person
consultations from a fee perspective
- appropriate fee for telemedicine consultation
- should give a receipt/invoice for the fee charged for
providing telemedicine-based consultation.

61. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
What is the role and responsibilities of
the technology platforms
(aggregators/online platforms)?

62. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Roles & Responsibilities
• Enrolling only ASU - RMP
• Qualifications and contact details should be displayed
• Grievance mechanism in place
• AI / ML platforms are prohibited consulting / counselling
and prescribing
• Online platforms can be blacklisted and ASU - RMPs
can be prohibited from using them for violation

63. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
How to avoid medico-legal issues online?
• Identify the patient by govt authorised ID
• Identify the emergency patient
• Please do diagnose / provisional diagnosis before you
prescribe
• Please follow the ‘prescribing list’ as per guidelines/ state
council laws
• Please retain a copy of all the investigation and prescription
you have offered (physical form)
• Do not share patients’ data with anyone
• Legal issues will be similar to in-person consultation

64. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Critique on the Guidelines
Positive Aspects
• Patient friendly, simple but comprehensive
• Professional clinical freedom have been given to ASU
- RMP
• It cuts across all available digital format
• A fantabulous attempt have been made to reach the
rural patients
• One of the best guidelines in the world (in-terms user)
• Paradigm shift – it is going to change the way we
practice medicine
• A Game changer in healthcare industry

65. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Draw Back
Draw Back - Silent About
• If patient releases the ASU - RMPs video/audio without his
consent
• Location of complaint (ASU - RMP or patient residence)
• insurance for teleconsultation
• Aggregators/storing & owner of the data
• Online platforms advertising doctors and rating of doctors
• Clinical Establishment Act V/s Telemedicine guidelines

66. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
To conclude
an idea whose time has come
this is solution for better care at home or at work
Become a Member of
Telemedicine Society of India - NOW

67. Adapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada MathAdapted from Telemedicine Practice Guidelines 2020 by Dr Suresh Bada Math
Thank You