South African Medical Association

Med-e-Mail:Update on the HPCSA's latest position on Telemedicine, dated 3 April 2020



Update on the HPCSA’s latest position on Telemedicine, dated 3 April 2020

- Anton van Schalkwyk (Medical Coding Specialist, SAMA)

As the South African medical profession is gearing itself for what could potentially be a large outbreak of COVID-19, our practitioners are all grappling with the question on how handle this pandemic within the confines of their individual practices.

The following information is important to take note of from the 3 April release by the HPCSA regarding Telemedicine during the COVID-19 outbreak:

In view of the above and after consultation with the twelve(12) Professional Boards under the ambit of the HPCSA the following provisions are hereby amended:

Clause (b) of the Guidance on the Application of Telemedicine Guidelines During the COVID-19 Pandemic which stated:
“Telehealth is only permissible in circumstances where there is an already established practitioner-patient relationship, except where Telepsychology and/or Telepsychiatry is involved, in which case telehealth is permissible even without an established practitioner-patient relationship”.

Is hereby amended as follows:

Telehealth should preferably be practised in circumstances where there is an already established practitioner-patient relationship. Where such a relationship does not exist, practitioners may still consult using Telehealth provided that such consultations are done in the best clinical interest of patients.

Clause (c) which stated:
“Practitioners may charge a fee for services rendered through a telehealth platform.”

Is hereby amended as follows:

Although practitioners may charge fees for consultations undertaken through Telehealth platforms, the Council strongly cautions against practices that may amount to over-servicing, perverse incentives and supersession.

The following may be deducted from this latest release in terms of Clause (B) of the HPCSA Guidelines

1. The HPCSA still prefers that telehealth services should be rendered to known patients.

2. The HPCSA is willing accept under these unusual circumstances that doctors may consult via telephone or other platforms such as Skype with new patients, but that they must act in the best clinical interest of the patient. Often times the best clinical interest of the patient would still be to invite them for a face-to-face visit in the Rooms.

3. We should therefore caution all practitioners that the clinical interest of the patient must be of the utmost importance when deciding on the mode of contact and that the ethical rules and guidelines of good practice as enforced by the HPCSA should guide the profession to still deliver the highest possible standard of care to the people of South Africa under these difficult circumstances. Should the practitioner not be in a position to assist the patient with a face-to-face visit as would sometimes be clinically demanded, it would be best to refer such a patient to a facility that would be able to render such as service.

The second amendment discussed on the 3 April release comments on the fact that fees may be charged for these Telehealth consultations: “…the Council strongly cautions against practices that may amount to over-servicing, perverse incentives and supersession.”

The following may be deduced from this remark:

1. It is a stern reminder that the ethical rules of the HPCSA are still in effect and are still enforceable.

2. Coding-wise the following comments may be made:
- A telemedicine consultation cannot be clinically equated with a visit in the rooms where the doctor has the opportunity to conduct a full physical medical examination, perform an injection or other minor procedures that are included in items 0190-0193 of the Medical Doctors’ Coding Manual,
- It is therefore impossible to render the same quality of service during a remote consultation as is the case with a face-to-face visit in the rooms.
- One can therefore not code for a face-to-face visit as if the consultation was performed with the patient present in the rooms.

In light of the above, the coding division of SAMA therefore reasserts its previously published position that the following coding may be used for Telemedicine for each service rendered:

1. Practitioners should familiarise themselves with the coding positions of the different medical schemes with regards to Telemedicine. Some Schemes have developed their own in-house codes and/or platforms and with regards to these in-house developments the practitioner should follow their recommendations.

2. In the absence of any in-house developed codes or platforms by an individual scheme, the following coding should be adhered to in the Medical Doctors’ Coding Manual:

- For the Consultation by means of a telephone or video platforms (e.g. Skype)
Item 0130 Telephone Consultation (all hours).

- For the writing and sending of a Script to the patient or pharmacy of their choice. Item 0132 Consulting service, e.g. writing of repeat scripts or requesting routine pre-authorisation without the physical presence of the patient (needs not be face-to-face contact) (“Consultation” via SMS or electronic media included)

- For the writing of any special motivations demanded by the Medical Scheme
Item 0133 Writing of special motivations for procedures and treatment without the physical presence of a patient (includes report on the clinical condition of a patient) requested by or on behalf of a third party funder or its agent.


In SAMA’s communication of 6 April 2020 regarding the COVID-19 crisis and Telehealth, we referred to the necessity for doctors to legally protect themselves regarding both face-to-face visits in the rooms and making use of electronic means of consulting such as telephone and other platforms such as Skype. On the one hand they have to have contractual disclaimers in place that warn patients of the health risks to come into the consulting rooms for a visit because of the outbreak and thereby avoid action being taken by a patient that may become infected. On the other hand patients need to be made aware of the limitations of Telemedicine.

For both scenario’s the SAMA legal division prepared legal documents that may be used by our members. One of the benefits to being a SAMA member is to have free access to our legal advisors and their expertise. Please find the contractual disclaimers for use by doctors in private practice attached to the end of this article.


The South African Medical Association - Postal Address-The South African Medical Association P O Box 74789,Lynnwood Ridge Pretoria 0040, South Africa Physical address The South African Medical Association, Block F Castle Walk Corporate Park Nossob Street Erasmuskloof Ext3 Pretoria 0181,
South Africa

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