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Telepractice – Position Statement

(Revised as of June 1, 2020)

The Chief Medical Officer of Health has amended Directive 2 to state that health care providers may gradually restart non-essential and elective services. Directive 2 encourages health care providers, where possible, to limit the number of in-person visits for the safety of health care providers and their patients.

This position statement is intended as a temporary measure to provide members with guidance on telepractice as an alternative to in-person service during the COVID-19 pandemic. The College plans to develop a more comprehensive Telepractice Guideline in the near future.

What is Telepractice

Telepractice (also called virtual practice) can be defined as the use of technology to deliver healthcare services without direct contact between the practitioner and the patient. While technology continues to change, some examples of technology used in telepractice include telephone, email and video conferencing.

TCM and Telepractice

In the context of TCM, telepractice has its limitations. The The Traditional Chinese Medicine Act, 2006, defines the scope of traditional Chinese medicine as the assessment of body system disorders through traditional Chinese medicine techniques and treatment using traditional Chinese medicine therapies to promote, maintain or restore health.

Furthermore, under the College's Standard for Diagnosis and Treatment, R. TCMPs and R. Acs must be able to accurately assess body system disorders through traditional Chinese medicine techniques.

Key Points:

  • As regulated health professionals, members of this College must use their professional judgement to determine whether virtual care is appropriate for the patient.
  • Practitioners who engage in telepractice must ensure they have the competencies (knowledge, skills, and judgment) to provide safe and effective virtual care to their patients.
  • Practitioners need to recognize the limitations of telepractice, which may include, for example, the challenges of obtaining sufficient information to make a TCM diagnosis and limitations on providing treatments such as acupuncture, cupping, gua sha, and Tuina.
  • To manage patients' expectations, members should clearly explain their scope of practice and the limitations of telepractice. Patients rely on receiving safe and effective care, regardless of how the service is delivered. Practitioners must obtain patients’ consent and ensure that their patients understand the risks and limitations of virtual care.
  • Members engaged in telepractice are accountable for the care they provide to their patients. They must use their professional judgement to assess on a case-by-case basis if the use of telepractice is in the patient's best interest.
  • Members engaged in telepractice need to have a plan in place to deal with potential adverse events such as medical emergencies, or failure of the communication technology.

College Standards

As in any practice situation, Members who engage in telepractice must comply with all regulations and standards of practice of the College. Their patients must receive safe, competent and ethical care, regardless of how that care is delivered. When providing care, members must choose the tools that are the most appropriate for their patients.

Privacy and Confidentiality

Members are expected to keep all personal health information confidential as required by the College’s standards of practice and legislation. When engaging in telepractice, members must take measures to implement security mechanisms that protect their patients' personal health information. For example, members must ensure that their use of mobile phones and apps does not allow for accidental access or dissemination of the patient's information to unauthorized third parties. Members should also ensure they assess if the patient's setting and their own setting is one that provides a safe, secure, and confidential environment to discuss patient-related matters.

For more information pertaining to safeguarding personal health information, please see the office of the Information and Privacy Commissioner of Ontario.

Consent

The requirement for members to obtain patients' consent for treatment is the same for telepractice and in-person patient care. However, in addition to the necessary components of consent, members should also inform their patients about the risks associated with providing services in ways other than in-person interactions. This will ensure that members obtain full and informed consent before providing treatment electronically. For more information, please see the Standard for Consent.

Record keeping

Members engaged in telepractice are required to maintain patient records in accordance with the College's Standard for Record Keeping. Members must maintain comprehensive clinical records and document all patient encounters that take place through telepractice. If applicable, patient records should clearly indicate that a service was provided remotely. For more information, please see the Standard for Record Keeping.

Fees and Billing

Members are already required to proactively advise patients of fees and costs. However, members are also expected to advise their patients (upfront) of any additional fees associated with telepractice. Invoices should be an accurate representation of the service provided to the patient. If applicable, an invoice should indicate that a service was provided remotely. It is the members' responsibility to advise their patients to check that the services provided by telepractice are covered by insurance providers.

Where possible, members should also ensure these fees are posted so that patients have all relevant information to make informed decisions. For more information, please see the Standard for Advertising.

Professional Liability Insurance (PLI)

Practitioners are required to maintain Professional Liability Insurance coverage as specified in the College By-Laws. When engaged in telepractice, practitioners must ensure that their PLI policies offer adequate coverage for that type of service delivery. For more information, please see the Professional Liability Insurance Policy.

References

College of Physiotherapists of Ontario (2020).Tele-practice: Guidelines and Resources for Physiotherapists.

The College of Traditional Chinese Medicine Practitioners and Acupuncturists of British Columbia (2020). Practice Standard Tele-Practice During the Coronavirus (COVID-19) Pandemic.

What is Telepractice

Telepractice (also called virtual practice) can be defined as the use of technology to deliver healthcare services without direct contact between the practitioner and the patient. While technology continues to change, some examples of technology used in telepractice include telephone, email and video conferencing.

TCM and Telepractice

In the context of TCM, telepractice has its limitations. The Traditional Chinese Medicine Act, 2006, defines the scope of traditional Chinese medicine as the assessment of body system disorders through traditional Chinese medicine techniques and treatment using traditional Chinese medicine therapies to promote, maintain or restore health.

Furthermore, under the College's Standard for Diagnosis and Treatment, TCM practitioners must effectively perform a physical assessment of the patient for the purpose of health promotion, diagnosis and/or management that is relevant and accurate.

Many TCM assessments (such as smelling, palpation, and pulse-taking), require in-person contact and cannot be done remotely. As such, telepractice is not a comparable alternative for an in-person TCM visit.

In some cases, it may be appropriate to use telepractice to monitor an existing patient or to provide an opportunity for the patient to communicate with the practitioner. However, it would not be appropriate to use telepractice to perform a physical assessment of the patient for the purpose of performing a TCM diagnosis and subsequent treatment. Telepractice is not appropriate for treatments such as acupuncture, cupping, gua sha, and Tuina.

Members engaged in telepractice are accountable for the care they provide to their patients. They must use their professional judgement to assess if the use of telepractice is in the patient's best interest. They must consider each patient's condition and their individual needs. To manage patients' expectations, members should clearly explain their scope of practice and the limitations of telepractice.

College Standards

As in any practice situation, Members who engage in telepractice must comply with all regulations and standards of practice of the College. Their patients must receive safe, competent and ethical care, regardless of how that care is delivered. When providing care, members must choose the tools that are the most appropriate for their patients.

Privacy and Confidentiality

Members are expected to keep all personal health information confidential as required by the College’s standards of practice and legislation. When engaging in telepractice, members must take measures to implement security mechanisms that protect their patients' personal health information. For example, members must ensure that their use of mobile phones and apps does not allow for accidental access or dissemination of the patient's information to unauthorized third parties. Members should also ensure they assess if the patient's setting and their own setting is one that provides a safe, secure, and confidential environment to discuss patient-related matters.

For more information pertaining to safeguarding personal health information, please see the office of the Information and Privacy Commissioner of Ontario.

Consent

The requirement for members to obtain patients' consent is the same for telepractice and in-person patient care. Members should inform their patients about the risks associated with providing services in ways other than in-person interactions. For more information, please see the Standard for Consent.

Record keeping

Members engaged in telepractice are required to maintain patient records in accordance with the College's Standard for Record Keeping. Members must maintain comprehensive clinical records and document all patient encounters that take place through telepractice.

Fees and Billing

Members are expected to advise their patients (upfront) of all fees associated with telepractice. Where possible, members should also ensure these fees are posted so that patients have all relevant information to make informed decisions. For more information, please see the Standard for Advertising.

References

College of Naturopaths of Ontario (2020). Regulatory Guidance Telepractice - Providing Naturopathic Care at a Distance.

College of Occupational Therapists of Ontario (2017). Guidelines for Telepractice in Occupational Therapy.

College of Physiotherapists of Ontario (2020). Tele-practice: Guidelines and Resources for Physiotherapists.

The College of Traditional Chinese Medicine Practitioners and Acupuncturists of British Columbia (2020). College’s Statement Regarding Tele-Practice During the COVID-19 Pandemic March 18, 2020.

College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario. Standard for Diagnosis and Treatment (2013).