On 26 March 2020 – the eve of the 21 day nationwide lockdown in South Africa – the Health Professions Council of South Africa (HPCSA) issued a guidance note regarding the practice of telemedicine.

The guidance note supplements and amends the HPCSA’s existing guidelines for the practice of telemedicine (booklet 10) as follows:

  • The term ‘telemedicine’ is replaced with ‘telehealth’, which incorporates telemedicine, telepsychology, telepsychiatry , telerehabilitation, ‘etc’. The list of disciplines in the guidance note is not exhaustive. The use of the term ‘etc’ in the note suggests that many other forms of telehealth are contemplated.
  • Telehealth is only permissible in circumstances where there is an established practitioner-patient relationship. This does not apply to telepsychology or telepsychiatry, which is permissible even if no established relationship exists.
  • Practitioners may charge a fee for services rendered through a telehealth platform.
  • Where practitioners are in doubt as to whether a telehealth consultation will be in the best interests of the patient, they are encouraged to advise patients to present themselves for a face-to-face consultation at a healthcare facility closest to the patient. Recently published lockdown regulations allow patients to leave their residence to obtain an essential service (which includes medical, health, mental health and laboratory services) or seek emergency, life-saving, or chronic medical attention.

The guidance note only applies during the COVID-19 pandemic, and the HPCSA will inform practitioners when the note ceases to apply.