Teleconsultation rules every Indian clinic should know

India's Telemedicine Practice Guidelines were published on 25 March 2020 by the Ministry of Health and Family Welfare, prepared by the Board of Governors of the Medical Council of India with NITI Aayog. They ended years of ambiguity about whether remote consultation was lawful at all.

They also set conditions. Six years on, plenty of clinics run teleconsultation without having read them.

Who may consult

Only practitioners registered with the National Medical Commission or a State Medical Council may practise telemedicine — Registered Medical Practitioners, MBBS and above.

This sounds obvious until you look at how clinics actually staff a phone line. A nurse relaying symptoms to a doctor and reading back instructions is not a teleconsultation, and should not be recorded or billed as one.

The first consultation may be remote

A widely held belief is that the first visit must be in person. It need not. A registered practitioner may conduct a first consultation remotely, and may do so for a patient located in any state.

What does not change is the standard of care. The guidelines are explicit that a teleconsultation must meet the same standard as an in-person consultation — and that the practitioner must use professional judgement about whether remote assessment is adequate at all. "The patient booked a teleconsultation" is not a defence for managing something that needed examination.

Consent

Consent is implied when the patient initiates the consultation. When the practitioner or the clinic initiates it, explicit consent is required and should be recorded.

For a clinic running follow-up call-backs — a pharmacy refill reminder that turns into a consultation, say — that distinction is the one to get right, because the clinic initiated it.

What may not be prescribed

This is the section with the sharpest edges.

• Prohibited outright: habit-forming drugs listed in Schedule X of the Drugs and Cosmetics Rules, 1945, and narcotic and psychotropic substances regulated under the NDPS Act, 1985. These cannot be prescribed via teleconsultation through any medium.
• List B drugs: permitted only in a tele follow-up consultation, not a first remote consultation.
• A separate prohibited list applies regardless of consultation type.

A clinic that runs teleconsultation should have these restrictions built into the prescribing screen rather than into a doctor's memory. Software that will let a doctor issue a Schedule X prescription from a video call is software that has left a compliance failure sitting in the workflow.

Technology and records

The guidelines require that teleconsultations use platforms that protect patient privacy and confidentiality. In practice that rules out the arrangement most small clinics default to: a personal WhatsApp account, on a phone shared between staff, with prescriptions sent as photographs.

That setup fails on privacy, on record-keeping, and — from May 2027 — on the DPDP Rules' security safeguard obligations at the same time.

Records of teleconsultations should be maintained the same way in-person consultations are: identifiable, retained, and auditable.

A workable clinic policy

If you are formalising teleconsultation, five decisions cover most of it:

1. Which practitioners are permitted to consult remotely, verified against their council registration.
2. Which presentations are eligible, and which always require an in-person visit.
3. How consent is captured, with a distinction between patient-initiated and clinic-initiated.
4. A prescribing block for Schedule X and NDPS drugs that the software enforces.
5. Where the record lands — the same patient file as an in-person visit, not a separate app.

Why this is worth the effort

Teleconsultation is genuinely useful in Indian practice — follow-ups, report reviews, chronic medication adjustments, and the enormous category of patients who travel two hours for a five-minute conversation.

The guidelines are not an obstacle to that. They are a description of how to do it defensibly. The clinics that get into trouble are not the ones consulting remotely; they are the ones doing it with no policy, no records, and a prescribing pad with no guardrails.

This summarises published guidance and is not legal advice. Confirm current requirements with the NMC before setting clinic policy.