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The College’s Telemedicine policy received final approval from Council on December 4, 2014, and is now an official policy of the College of Physicians and Surgeons of Ontario.
We would like to thank all those who submitted their feedback and contributed to this policy review. While not every comment or suggested edit was incorporated into the final policy, all comments were carefully considered in light of current practice issues, the values and duties of medical professionalism, and the College’s mandate to protect the public.
Below is a brief summary of the policy review process, including an overview of the feedback received and revisions undertaken:
Who we heard from
93 submissions were received in response to this consultation.
While the majority of feedback was submitted by physicians, we also heard from a number of other important stakeholders, including members of the public and key organizations, such as the Ontario Telemedicine Network and Canada Health Infoway.
Broadly speaking, respondents expressed support for the policy.
The majority of respondents thought the policy was clear and comprehensive, and were generally supportive of the expectations set out within.
Of those respondents who provided constructive criticism on the draft policy, many suggested the following:
The terminology and definitions used in the draft policy should be refined to improve the precision and clarity of the policy.
The draft policy should include specific expectations for telemedicine in relation to areas of practice (e.g. specify the requirements/limitations for the use of telemedicine in various types of care/practice settings).
Some of the conditions for the appropriate use of telemedicine should contain more specific direction and/or be clarified (e.g. specify which technologies should be used, and which technologies are currently secure and unsecure).
In addition to the feedback, we considered a wide range of other information while developing the final policy. This included:
Policies and guidelines of other medical regulators within Canada and internationally, and other health regulators within Ontario.
An extensive literature review which focused on a range of issues related to telemedicine, including known uses of telemedicine, the benefits and limitations of providing care in this manner, and technology and security considerations with respect to the equipment used to conduct telemedicine.
Research into jurisdictional issues with respect to medical licensure and regulatory oversight for telemedicine provided across borders, and relevant legal issues.
How we responded to your feedback
A number of revisions, additions, and deletions were made to the draft policy in response to your feedback. The majority aimed to improve the overall clarity of the policy and the expectations set out within.
Two of the more significant revisions are highlighted below, as are two important instances where revisions were not made:
The policy clarifies that the expectations set out within apply in all instances when telemedicine is practised, regardless of the specific area of practice or practice setting in which telemedicine is used..
The policy articulates elements of appropriate conduct that are applicable and need to be satisfied in every instance in which telemedicine in practised. This is consistent with the CPSO’s approach to policy more generally (i.e. to set out general principles/expectations).
The policy clarifies what is expected of CPSO members with respect to licensure in other jurisdictions and out-of-province consultations and referrals.
CPSO members must be aware of, and comply with, the licensing requirements in both the physician’s and patient’s jurisdiction.
CPSO members must be aware that consultations include sending patient information (e.g. diagnostic images or tests) to out-of-province physicians for an opinion.
The scope of the policy was not limited to physician-patient interactions via telemedicine as proposed by some respondents.
The same policy expectations applicable to physician-patient interactions would apply equally to any interactions between physicians and other health care providers (e.g. consultations or referrals).
Specific expectations regarding technical specifications and security were not included in the policy.
Footnotes in the policy reference resources for security standards and state that physicians may consult with an information and communication technology and/or privacy expert if they are unsure as to whether the technology and/or physical setting is secure.
The policy purposefully avoids naming which technologies should be used and which are currently secure and unsecure, as the list would not be up-to-date or exhaustive given the fact that technology is constantly evolving.
The policy applies broadly to the practice of telemedicine, regardless of the specific area of practice or practice setting in which telemedicine is used.
The practice of telemedicine is the practice of medicine; physicians’ existing legal and professional obligations with respect to practising the profession are not altered simply because care is provided via telemedicine as opposed to in-person.
Physicians must use their professional judgment to determine whether telemedicine is appropriate in a particular circumstance each and every time its use is contemplated for patient care, consultations and referrals.