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Telemedicine guidelines India: what a clinic doctor may do The 2020 Telemedicine Practice Guidelines, read for the OPD desk.

Patients call, send photos on WhatsApp and ask for a repeat prescription over the phone. The Telemedicine Practice Guidelines of 25 March 2020 say what a registered doctor may do in each of those cases. We read the Gazette text and set out the parts a clinic doctor needs.

Shaurya Pratap SinghFounder, Vitels

Published · Last reviewed · 19 min read

In short
  • Only a Registered Medical Practitioner may consult by telemedicine, by video, audio or text, and the same ethics and standard of care apply as in the clinic. Patient consent is implied when the patient starts the consult; it must be explicit, and recorded, when a doctor, health worker or caregiver starts it.
  • What may be prescribed depends on the mode and on whether it is a first consult or a follow-up within 6 months. List O works on any mode, List A needs video for a first consult, List B is for add-ons at follow-up, and Schedule X drugs and narcotics are prohibited. Prescribing without a diagnosis or provisional diagnosis is misconduct.
  • The record of a teleconsult is kept exactly as an in-person record: the call or chat log, the information used, and the prescription. A fee may be charged and a receipt must be given. The guidelines are still the 2020 text; the 2023 NMC regulations that restated them are in abeyance.

The telemedicine guidelines India follows are the Telemedicine Practice Guidelines dated 25 March 2020, which sit as Appendix 5 of the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002. They let any Registered Medical Practitioner consult patients anywhere in India by video, audio or text, with the same professional duties as an in-person visit. What you may prescribe depends on the mode you use and on whether the patient is new to you or a follow-up within 6 months. Everything below comes from the Gazette copy; where the text is clinical, we quote it and leave the judgement to you.

Where the rule comes from, and whether it has changed since 2020

The Board of Governors in supersession of the Medical Council of India added regulation 3.8, "Consultation by Telemedicine", to the 2002 regulations by the Indian Medical Council (Professional Conduct, Etiquette and Ethics) (Amendment) Regulations, 2020, notification No. MCI-211(2)/2019(Ethics)/100659 dated 12 May 2020, published in the Gazette of India on 14 May 2020 and deemed effective from 25 March 2020. Regulation 3.8.1 says consultation through telemedicine by an RMP "shall be permissible in accordance with the Telemedicine Practice Guidelines contained in Appendix 5." Regulation 3.8.3 adds that the guidelines "are not applicable to the use of digital technology to conduct surgical or invasive procedure remotely."

The guidelines were restated inside the NMC's Registered Medical Practitioner (Professional Conduct) Regulations, 2023, notified on 2 August 2023, as regulation 29 and a schedule titled "Guidelines for Practice of Telemedicine in India". Those regulations were held "in abeyance with immediate effect" by a notification dated 23 August 2023 (Gazette No. 596, 24 August 2023), which also re-adopted the 2002 regulations. So the 2020 text is the one in force. We checked the NMC e-gazette listing and its circulars page on 26 October 2026 and found no later notification on telemedicine or on the drug lists. Regulation 3.8.4 allows the lists to be modified, so re-check the NMC site before relying on this post a year from now. Our guide to the NMC professional conduct regulations covers the 2002 and 2023 texts in full.

Who may consult by telemedicine

Only a Registered Medical Practitioner, defined in the guidelines as "a person who is enrolled in the State Medical Register or the Indian Medical Register under the IMC Act 1956". Paragraph 1.3.1 says an RMP "is entitled to provide telemedicine consultation to patients from any part of India", and 1.3.2 that RMPs using telemedicine "shall uphold the same professional and ethical norms and standards as applicable to traditional in-person care, within the intrinsic limitations of telemedicine." The scope section excludes consultations "outside the jurisdiction of India". If you are not yet on a state register, our state medical councils guide explains first registration.

The guidelines also announce a course. Paragraph 1.3.3 says "an online program will be developed and made available by the Board of Governors", that "all registered medical practitioners intending to provide online consultation need to complete a mandatory online course within 3 years of its notification", and that "in the interim period, the principles mentioned in these guidelines need to be followed." As of 26 October 2026 we found no notice on nmc.org.in announcing that course or extending the deadline, so we cannot tell you its status. The 2023 version in abeyance drops the sentence and says instead that RMPs "need to undergo CPD training in telemedicine practice". Ask your state council if you want a definite answer.

Video, audio or text: which mode for what

Section 2 names three modes, video, audio and text, and paragraph 1.4.1 lists the tools an RMP may use: "telephone, video, devices connected over LAN, WAN, Internet, mobile or landline phones, Chat Platforms like WhatsApp, Facebook Messenger etc., or Mobile App or internet based digital platforms for telemedicine or data transmission systems like Skype/ email/ fax etc." A plain phone call and a WhatsApp chat are both telemedicine. The guidelines then say what each mode can and cannot do.

Strengths and limitations of each mode, as stated in section 2 of the guidelines
ModeWhat the guidelines say it is good forStated limitations
Video"Closest to an in person-consult"; patient identification is easier; the RMP can see the patient and the caregiver; "Inspection of patient can be carried out"Needs a good connection at both ends; privacy in video consults is "extremely important"
Audio (phone, VoIP)"Convenient and fast"; "Suitable for urgent cases"; no separate infrastructureNon-verbal cues missed; "Not suitable for conditions that require a visual inspection (e.g. skin, eye or tongue examination), or physical touch"; identity needs to be clearer, "greater chance of imposters"
Text (WhatsApp, SMS, chat apps)"Convenient and quick"; suitable for urgent cases, follow-ups and second opinions "provided RMP has enough context from other sources"Misses visual, physical and verbal cues; hard to build rapport; "Cannot be sure of identity of the doctor or the patient"
Asynchronous (email, fax, recordings)Easy to document; images and reports readily shared; useful with test reportsOne-way context only; identification "is document based only"; delays because the doctor may not see the mail at once

The choice is yours, but the guidelines fix the floor. Paragraph 3.1.1 asks you to "consider the mode/technologies available and their adequacy for a diagnosis before choosing to proceed". Paragraph 3.3.3 says that where "the RMP needs to visually examine the patient and make a diagnosis", the RMP "could recommend a video consultation". The patient-evaluation section is firmer: "If a physical examination is critical information for consultation, RMP should not proceed until a physical examination can be arranged through an in-person consult", and where necessary the RMP shall recommend a video consultation, examination by another RMP or health worker, or an in-person visit. The framework in section 4 puts it in one line: "If a case requires a video consultation for examination, RMP should explicitly ask for it." Video is also the only mode on which List A medicines may be prescribed at a first consult, covered below.

First consult or follow-up: the 6-month rule

Paragraph 3.6.1 defines a first consult as one where the patient is consulting the RMP for the first time, or "has consulted with the RMP earlier, but more than 6 months have lapsed since the previous consultation", or has consulted earlier "but for a different health condition". A follow-up under 3.6.2 is when "the patient is consulting with the same RMP within 6 months of his/her previous in-person consultation and this is for continuation of care of the same health condition." It stops being a follow-up if "there are new symptoms that are not in the spectrum of the same health condition" or the "RMP does not recall the context of previous treatment and advice."

Two things follow for an OPD. The 6 months run from the last in-person visit, so a patient who has only ever consulted you on the phone does not become a follow-up patient. And the clock is per condition: a known diabetic calling about a new complaint is, for that complaint, a first consult. This is why the visit date and the diagnosis on your record matter for every phone call, which our OPD workflow post covers from the front-desk side.

Paragraph 3.2.1 says a teleconsultation "should not be anonymous: both patient and the RMP need to know each other's identity." The RMP "should verify and confirm patient's identity by name, age, address, email ID, phone number, registered ID or any other identification as may be deemed to be appropriate" (3.2.2), and "should begin the consultation by informing the patient about his/her name and qualifications" (3.2.4). For a prescription, 3.2.3 says the RMP "needs to explicitly ask the age of the patient, and if there is any doubt, seek age proof", and where the patient is a minor, "tele consultation would be allowed only if the minor is consulting along-with an adult whose identity needs to be ascertained." Paragraph 3.2.5 extends the registration-number rule to "prescriptions, website, electronic communication (WhatsApp/ email etc.) and receipts". For a follow-up, the framework accepts that the RMP is "reasonably convinced" it is the known patient, for example because the message comes from "the registered phone number or registered email Id", and may ask the patient to reinitiate from that number if in doubt.

Consent under 3.4 comes in two forms. "If, the patient initiates the telemedicine consultation, then the consent is implied", on the same footing as a patient walking into the OPD. "An Explicit patient consent is needed if: A Health worker, RMP or a Caregiver initiates a Telemedicine consultation." Explicit consent "can be recorded in any form": an email, a text, an audio or video message, or the patient saying something like "Yes, I consent to avail consultation via telemedicine" on the call. Then the key line for the clinic: "The RMP must record this in his patient records." If your clinic calls a patient back after a missed appointment and consults on that call, the clinic started it, so note the consent. The telemedicine consent is separate from the data-protection notice and consent that the DPDP Act asks of clinics.

Can a doctor prescribe over WhatsApp? The four drug lists

Yes, within limits set by the mode and the type of consult. Paragraph 3.7.4 says prescribing by telemedicine "is at the professional discretion of the RMP" and "entails the same professional accountability as in the traditional in-person consult." An RMP "may prescribe medicines via telemedicine ONLY when RMP is satisfied that he/ she has gathered adequate and relevant information about the patient's medical condition", and "Prescribing Medicines without an appropriate diagnosis/provisional diagnosis will amount to a professional misconduct." Then come the four lists, which we quote as written. The named examples in the Gazette's Annexure 1 are the regulator's illustrations; we leave them to the source and do not add any.

  • List O: "those medicines which are safe to be prescribed through any mode of tele-consultation", meaning "Medicines which are used for common conditions and are often available 'over the counter'" and "Medicines that may be deemed necessary during public health emergencies."
  • List A: medicines "which can be prescribed during the first consult which is a video consultation and are being re-prescribed for re-fill, in case of follow-up." The text calls it "an inclusion list, containing relatively safe medicines with low potential for abuse".
  • List B: "a list of medication which RMP can prescribe in a patient who is undergoing follow-up consultation in addition to those which have been prescribed during in-person consult for the same medical condition."
  • Prohibited List: medicines an RMP consulting by telemedicine "cannot prescribe", because they "have a high potential of abuse and could harm the patient or the society at large if used improperly": "Medicines listed in Schedule X of Drug and Cosmetic Act and Rules or any Narcotic and Psychotropic substance listed in the Narcotic Drugs and Psychotropic Substances, Act, 1985".
Matrix of the permissible drug lists by mode and type of consultation, from section 3.7.4 of the guidelines
ListMode of consultationNature of consultation
OAnyAny
AVideoFirst consultation; follow-up for continuation of medications
BAnyFollow-up
ProhibitedNot to be prescribedNot to be prescribed

Put against the OPD day: on a WhatsApp chat or a phone call with a new patient, the guidelines allow List O only. A first consult on video opens List A as well. A follow-up patient, within 6 months of an in-person visit for the same condition, may have the earlier medicines re-prescribed for a refill on any mode, and an add-on under List B. The framework for a follow-up says that if the consult "reveals new symptom pertaining to a different spectrum of disease, then the RMP would proceed with the condition as enunciated in the scenario for a first-time consultation." The misconduct section lists "RMPs who use telemedicine to prescribe medicines from the specific restricted list" as an action that is "explicitly not permissible", alongside misusing patient images and insisting on telemedicine when the patient is willing to come in. Read Annexure 1 yourself before you settle your own clinic's practice; nothing here is a substitute for it.

The prescription: format, signature and how to send it

The guidelines do not create a new prescription law. If medicines are prescribed, the RMP "shall issue a prescription as per the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations and shall not contravene the provisions of the Drugs and Cosmetics Act and Rules." Regulation 1.5 of the 2002 regulations, as substituted on 8 October 2016, says every physician "should prescribe drugs with generic names legibly and preferably in capital letters". Annexure 2 of the guidelines gives a sample format: the RMP's name, qualification, registration number, address and contact details at the top; date of consultation, patient name, age, gender, address, with height, weight and LMP where applicable; chief complaints, relevant history, examination or lab findings, suggested investigations; diagnosis or provisional diagnosis; each medicine as "NAME OF MEDICINE (in capital letters only with generic name) drug form, strength, frequency of administration & duration"; special instructions; "RMPs Signature & Stamp"; and a footer note, "This prescription is generated on a teleconsultation."

On sending it: the RMP "shall provide photo, scan, digital copy of a signed prescription or e-Prescription to the patient via email or any messaging platform." The guidelines do not define a signature standard beyond "signed" and "e-Prescription"; a photographed, signed and stamped paper prescription meets the words of the text. If you send the prescription straight to a pharmacy, you "must ensure explicit consent of the patient that entitles him/her to get the medicines dispensed from any pharmacy of his/ her choice." Our prescription format tool lays out the standard fields for a printed pad; add the teleconsultation note by hand when you use it for a phone consult.

Records to keep, and for how long

The duties section says it is "incumbent on RMP to maintain the following records/ documents for the period as prescribed from time to time": a "Log or record of Telemedicine interaction (e.g. Phone logs, email records, chat/ text record, video interaction logs etc.)"; the "Patient records, reports, documents, images, diagnostics, data etc. (Digital or non-Digital) utilized in the telemedicine consultation"; and, where a prescription was shared, "the prescription records as required for in-person consultations." The guidelines set no separate retention period for teleconsults; they point back to the ordinary rules. The 2002 regulations fix 3 years for indoor records (1.3.1) and a 72-hour window to hand over records on request (1.3.2), and your state's clinical establishments rules may say more. Our post on how long a clinic must keep medical records sets out the periods and a retention policy for a small OPD.

Two more lines matter for a clinic that uses WhatsApp. The RMP must "fully abide by" the 2002 regulations and "the relevant provisions of the IT Act, Data protection and privacy laws or any applicable rules notified from time to time". And a footnote warns against adding patients to a virtual support group "without their consent". The guidelines also say an RMP "will not be held responsible for breach of confidentiality if there is a reasonable evidence to believe that patient's privacy and confidentiality has been compromised by a technology breach or by a person other than RMP", provided "reasonable degree of care" was taken in hiring such services.

Fees, receipts and emergencies

Fees are simple. "Telemedicine consultations should be treated the same way as in-person consultations from a fee perspective: RMP may charge an appropriate fee for the Telemedicine consultation provided", and "An RMP should also give a receipt/invoice for the fee charged". Use the receipt you give at the counter, set out in our post on what a clinic bill must include, and put your registration number on it, as 3.2.5 asks.

Emergencies are where telemedicine stops. Section 4.5 says the goal "should be to provide in-person care at the soonest", that the RMP may "Advise first aid", "Counseling" and "Facilitate referral", and that "In all cases of emergency, the patient MUST be advised for an in-person interaction with a Registered Medical Practitioner at the earliest". Paragraph 1.4.2.3 adds that telemedicine "should however be avoided for emergency care when alternative in-person care is available". Every flow in section 4 starts with a quick assessment for an emergency before anything else.

Caregivers, health workers and another doctor

A caregiver "could be a family member, or any person authorized by the patient to represent the patient." Where the patient is present with the caregiver, the consult proceeds as a normal first or follow-up consult. Where the patient is not present, the guidelines allow it in two cases: the patient "is a minor (aged 16 or less) or the patient is incapacitated, for example, in medical conditions like dementia or physical disability", in which case "the care giver is deemed to be authorized"; or the caregiver "has a formal authorization or a verified document establishing his relationship with the patient and/or has been verified by the patient in a previous in-person consult". Because a caregiver, not the patient, starts the consult, consent is explicit and must be recorded.

A health worker, defined as a "Nurse, Allied Health Professional, Mid-Level Health Practitioner, ANM or any other health worker designated by an appropriate authority", may facilitate a consult for a patient they have seen, including at health camps, home visits and mobile units. The health worker "should obtain the patient's informed consent", confirm identity, and the RMP must again confirm identity and "confirm the patient's consent to continue the consultation". An RMP may also consult another RMP or specialist about a patient; the RMP asking "remains the treating RMP and shall be responsible for treatment and other recommendations given to the patient."

Platforms, apps and AI

Section 5 covers "technology platforms which work across a network of Registered medical practitioners and enable patients to consult with RMPs through the platform". Such platforms must make sure consumers consult registered doctors, conduct due diligence before listing an RMP, and "provide the name, qualification and registration number, contact details of every RMP listed". Paragraph 5.4 is the one to remember: "Technology Platforms based on Artificial Intelligence/Machine Learning are not allowed to counsel the patients or prescribe any medicines to a patient. Only a RMP is entitled to counsel or prescribe and has to directly communicate with the patient in this regard." Decision-support tools may assist, but "the final prescription or counseling has to be directly delivered by the RMP". A platform found in violation may be blacklisted, after which "no RMP may then use that platform to provide telemedicine". The guidelines also bar RMPs from soliciting patients for telemedicine "through any advertisements or inducements"; the wider rules on doctor advertising are in our NMC advertising guidelines post.

Three situations at the OPD desk

What the guidelines say about mode, consent and prescribing in three common situations (no clinical advice; read Annexure 1 for the lists)
SituationModeConsent and identityPrescribing
A new patient messages a photo of a rash on WhatsApp and asks for medicineText is a permitted mode, but audio and text are listed as unsuitable for conditions that need visual inspection such as skin. The guidelines say to ask for video explicitly if examination is needed, or an in-person visit.Patient initiated, so consent is implied. Confirm name, age, address and phone number; ask age before any prescription; a minor must be with an identified adult.This is a first consult. On text only, List O. If moved to video, List A becomes available. Prescribing without a diagnosis or provisional diagnosis is misconduct.
A follow-up patient calls and asks to repeat the last prescriptionAny mode, provided the last in-person visit for the same condition was within 6 months and you have the record. The guidelines list follow-ups among the uses of text, provided you have enough context.Implied, since the patient called. Be reasonably convinced it is the known patient, for example the registered number; ask them to call back from it if in doubt.Re-prescribe the original medicines for a refill (List A at follow-up); an add-on from List B is allowed. A new, unrelated symptom turns it into a first consult.
A parent calls about a childCaregiver to RMP. Choose the mode by what you need to examine; for a child who is not present, the caregiver is deemed authorised for a minor aged 16 or less.A caregiver started the consult, so consent is explicit and must be recorded. Confirm the caregiver's identity and the child's name and age.Then the consult follows the first or follow-up rules above, with the same lists and the same mode limits.
  1. Note who started the consult. Patient-initiated means implied consent; clinic, caregiver or health worker initiated means explicit consent, written into the record in the patient's words or as a saved message.
  2. Confirm and write down the patient's name, age, address and phone number, and for a follow-up the fact that the message came from the registered number. Note the adult's identity for a minor.
  3. Record the mode used (video, audio, WhatsApp, email) and the date and time, and keep the call log, chat or email as the log of the interaction.
  4. Record what you relied on: the complaints, history, photos, reports and previous records, and whether you asked for more information or paused the consult.
  5. Mark the consult as first or follow-up against the last in-person visit date and the condition, and record the diagnosis or provisional diagnosis before any prescription.
  6. Keep a copy of the prescription you sent, with the teleconsultation note, in the same way you file an in-person prescription, and note where you sent it (patient, or pharmacy with explicit consent).
  7. Issue a receipt for the fee, with your registration number on it, and keep the copy with the day's collections.
  8. Keep all of the above for the same period as your in-person records, and treat the WhatsApp or email trail as patient data under your data-protection duties.

Questions

Can a doctor prescribe medicines over WhatsApp in India?

Yes, within the Telemedicine Practice Guidelines 2020. WhatsApp is a text mode. For a new patient on text, the guidelines allow List O medicines only, the ones used for common conditions and often available over the counter. For a follow-up within 6 months of an in-person visit for the same condition, the earlier medicines may be re-prescribed for a refill and a List B add-on may be given on any mode. Schedule X drugs and narcotic or psychotropic substances may never be prescribed by telemedicine, and prescribing without a diagnosis or provisional diagnosis is professional misconduct.

Is a video consultation compulsory for a first teleconsultation?

No. A first consult may be by video, audio or text, and the RMP decides which mode is adequate for a diagnosis. Video is required in effect when the RMP needs to see the patient to diagnose, when a case needs examination (the guidelines say to ask for video explicitly), and if any List A medicine is to be prescribed at a first consult. If a physical examination is critical, the RMP should not proceed until an in-person examination can be arranged.

Do I need the patient's written consent for a teleconsultation?

Not in writing. When the patient initiates the consult, consent is implied, as it is when a patient walks into the OPD. When a doctor, health worker or caregiver initiates it, explicit consent is needed; it can be an email, text, audio or video message, or the patient saying so on the call, and the RMP must record it in the patient record.

Can I charge a fee for a phone consultation?

Yes. The guidelines say telemedicine consultations are treated the same as in-person consultations from a fee perspective, that the RMP may charge an appropriate fee, and that the RMP should give a receipt or invoice for it. The receipt, like the prescription and any WhatsApp or email to the patient, should carry your registration number.

Sources

  1. Board of Governors in supersession of the Medical Council of India, Indian Medical Council (Professional Conduct, Etiquette and Ethics) (Amendment) Regulations, 2020, No. MCI-211(2)/2019(Ethics)/100659, 12 May 2020, with Appendix 5, Telemedicine Practice Guidelines, 25 March 2020; Gazette of India, Extraordinary, Part III, Section 4, No. 174, 14 May 2020 (CG-DL-E-14052020-219374) (accessed 26 Oct 2026)
  2. Ministry of Health and Family Welfare (eSanjeevani), Telemedicine Practice Guidelines, 25 March 2020 (standalone copy) (accessed 26 Oct 2026)
  3. National Medical Commission, Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002, amended up to 8 October 2016 (regulations 1.3, 1.5, 7.2, 7.3) (accessed 26 Oct 2026)
  4. National Medical Commission, Registered Medical Practitioners (Professional Conduct) (Amendment) Regulations, 2023, No. R-12013/01/2022/Ethics, 23 August 2023, Gazette of India No. 596, 24 August 2023 (regulations 2023 held in abeyance) (accessed 26 Oct 2026)
  5. National Medical Commission, Registered Medical Practitioner (Professional Conduct) Regulations, 2023, 2 August 2023, regulation 29 and the Guidelines for Practice of Telemedicine in India (Gazette copy; in abeyance) (accessed 26 Oct 2026)
  6. National Medical Commission, e-Gazette notifications listing and Circulars/Public Notices page (checked for any telemedicine notification after 2020) (accessed 26 Oct 2026)

This is operational guidance for clinics, not legal or tax advice. Confirm with your state authority, council or CA.

Drafted with AI assistance; every fact checked against the sources listed; reviewed by Shaurya Pratap Singh.

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