Virtual care standards and the regulation of telehealth

Digital health is already being utilised to improve access to care and deliver excellent outcomes for patients. However, for its continued adoption it needs to be delivered responsibly and with the appropriate guardrails in place.

The Australian Health Practitioner Regulation Agency (AHPRA) has released a statement raising concerns about the potential risk digital clinics pose to both patients and practitioners. Eucalyptus has been calling for a specific telehealth regulator for some time and we’re pleased to see moves in this direction from AHPRA. However, there are some ongoing myths and assertions within the regulator’s statement that have the potential to do more harm to the industry than good. While it’s clear there’s significant work left to be done to further improve the quality of the digital health industry, it’s imperative that this doesn’t stand in the way of progress at an industry level.

The value of virtual care models

It was encouraging to read several comments from the regulator which spoke directly to the value of virtual care models, including:

  • “Good prescribing must balance safety and access” 

This is an important principle and one we believe should be monitored by a newly formed telehealth regulatory body. It’s our stance that it should be mandatory for digital providers to provide prescribing rates, treatment outcomes and side effect occurrences, all of which sophisticated platforms like Eucalyptus already record and publish research on regularly.

  • "While the delivery of telehealth services is supported by AHPRA and the national boards, we do not support practitioners or health services taking advantage of patients or ignoring their obligations to provide appropriate care and follow-up when needed."

Again, a crucial principle, and an area where telehealth offers a unique advantage. Patients receiving obesity care from Eucalyptus gain access to a multidisciplinary team of health practitioners, including access to continuous clinical support. Throughout their program, patients can track side effects and outcomes through a purpose-built app, with oversight and assistance provided by their health practitioners. Mandating follow-up arrangements as part of a treatment plan should be an essential part of regulating telehealth.

Busting myths about virtual care

While the above assertions are promising, especially as a well established provider with sophisticated patient and practitioner platforms, there are still common themes circulating that continue to ignore the benefits of telehealth and set out to diminish the idea of running a business in healthcare:

  • The distinction that commercial telehealth is different to general telehealth is not helpful. Almost all healthcare organisations are and need to be commercial in order to continue supporting patients. That has long been the reality for large segments of the Australian health sector — long before the emergence of telehealth platforms.
  • The assertion that telehealth ‘prioritises profits over patients’ almost always fails to explain what quality patient care via telehealth should look like. Eucalyptus and our digital clinics are transparent about our outcomes, publishing these regularly, and have hundreds of thousands of patients who are happy with the services they are paying for. Assertions like this need to be backed by data and the voices of patients, not just mere supposition.
  • The notion that telehealth disrupts continuity of care is another concern that can be easily avoided. A simple starting point is mandating letters to regular practitioners when patients opt-in. Eucalyptus already provides this. It is also important to state that a digital relationship in and of itself doesn’t fracture continuity. There is an incredible opportunity to use technology for care continuity that simply cannot be ignored.
  • The suggestion that consumer demand is the touchstone of the prescribing decision both inaccurately targets the telehealth sector and undermines the agency and professionalism of the practitioner. Patients in both brick-and-mortar and telehealth clinics may seek out a particular medication or treatment for a specific condition, but it is the role of their practitioner to decide what is appropriate for them, in collaboration with the patient. Practitioners in Eucalyptus’s digital clinics will determine up to 40% of prospective patients for certain conditions to be unsuitable for a treatment plan through our service, and will instead refer those patients back to their community GP for further consultation and support. This simply underlines the gatekeeper role that practitioners have always played, and will continue to play.

We welcome critical discourse but in order to enact real change for patients and improve telehealth at a national level, we need to understand the above themes as only fragments of the whole story.

AHPRA’s decision is a crucial step forward for telehealth in Australia and we look forward to working with regulators on a path forward here, namely in the development of uniform quality and safety standards for virtual care. 


Dr Matt Vickers
Clinical Director
Lyndon Goddard
Senior Legal Counsel & Head of Public Policy