Dr Asher Freilich
Chief Executive Officer
InstantScripts
Level 19, 644 Chapel Street,
SOUTH YARRA VIC 3141
Via email: xxxxx.xxxxxxxx@xxxxxxxxxxxxxx.xxx.xx
Dear Dr Freilich
Online prescriptions update from InstantScripts
The Medical Board of Australia (the Board) has considered information on the InstantScripts website at
https://www.instantscripts.com.au/online-scripts that provides information that patients can obtain ongoing
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online prescriptions if they have had one telephone consultation with a doctor from InstantScripts.
The Board confirmed that the advice on the InstantScripts website is not consistent with the Board’s
Guidelines: Telehealth consultations with patients.
The Guidelines state:
Prescribing or providing healthcare if you have never had a real-time consultation with the
patient
Prescribing or providing healthcare for a patient without a real-time direct consultation, whether in-
person, via video or telephone, is not good practice and is not supported by the Board.
Information
This includes asynchronous requests for medication communicated by text, email, live-chat or
of
online that do not take place in the context of a real-time continuous consultation and are based
on the patient completing a health questionnaire, when the practitioner has never spoken with the
patient.
Any practitioner who prescribes for patients in these circumstances must be able to explain how
the prescribing and the management of the patient was appropriate and necessary in the
circumstances.
The Board recognises that it may be appropriate for a patient’s usual medical practitioner or
another health practitioner with access to the patient’s clinical record to prescribe without a
consultation in certain circumstances.
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The final paragraph in the advice refers to the very occasional circumstance where a patient cannot attend
a synchronous telehealth consultation but is a longstanding patient of a practitioner and provides for the
writing of a short-term prescription to tide the patient over until they can have a synchronous telehealth or
in person consultation.
A single telephone consultation with a doctor at a company such as InstantScripts is not the same as
Ahpra
being the patient’s usual medical practitioner. A doctor who prescribes asynchronously in circumstances
where there had been a single telehealth consultation with another doctor would need to explain how the
prescribing and management of the patient was appropriate and necessary in the circumstances if a
notification was made.
Australian Health Practitioner Regulation Agency
National Boards
GPO Box 9958 Melbourne VIC 3001 Ahpra.gov.au 1300 419 495
Ahpra and the National Boards regulate these registered health professions: Aboriginal and Torres Strait Islander
health practice, Chinese medicine, chiropractic, dental, medical, medical radiation practice, midwifery, nursing,
occupational therapy, optometry, osteopathy, paramedicine, pharmacy, physiotherapy, podiatry and psychology.
The Board is writing to you as a courtesy as the proposed approach from InstantScripts may be putting
the medical practitioners that are writing prescriptions in the circumstances you have described at risk of
regulatory action.
The Board wil also confirm this advice in its upcoming newsletter so that all medical practitioners are
aware that asynchronous prescribing outside the ongoing therapeutic relationship may put them at risk of
regulatory action.
Yours sincerely
Dr Joanne Katsoris
Executive Officer, Medical
Australian Health Practitioner Regulation Agency
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Information
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Ahpra
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