Key Takeaways
- AHPRA released updated telehealth and virtual care guidance on 7 October 2025, applying across all 15 National Boards rather than just the Medical Board, and explicitly targeting questionnaire-only and asynchronous prescribing models.
- The Boards' position is now unambiguous: prescribing for a patient a practitioner has never consulted in real time (face-to-face, video or telephone) is not good practice. An online chat does not count as a real-time consult.
- AHPRA originally suggested only face-to-face consults qualified as good practice. After pushback, it clarified on 9 October 2025 that face-to-face, video, or telephone all qualify, aligning with the existing Medical Board telehealth guidelines in force since 1 September 2023.
- The high-risk models specifically flagged are weight loss medication, peptides, medicinal cannabis and cosmetic prescribing, especially where they sit inside vertically integrated clinic-pharmacy business models.
- Major medical defence organisations are now refusing indemnity for completely asynchronous prescribing. MIGA has confirmed it will not cover doctors prescribing medicinal cannabis or peptides via telehealth without an established therapeutic relationship.
- AHPRA is monitoring these models proactively (without waiting for patient complaints), and a 2020 tribunal already produced a GP reprimand for inappropriate online prescribing under the existing law, well before the October 2025 tightening.
- Every practice that offers telehealth, refers to online prescribing services, or hosts a co-located cosmetic or weight management clinic should review its real-time consultation, identity verification, record-keeping and RTPM (real-time prescription monitoring) workflows by 30 June 2026.
AHPRA's October 2025 telehealth guidance update makes it clear that prescribing without a real-time consultation, including questionnaire-only and asynchronous models, is not considered good practice. From October 2025, every Board (not just the Medical Board) has adopted this position, indemnity insurers have followed, and high-risk areas like weight loss, peptides, medicinal cannabis and cosmetic prescribing are under active scrutiny in 2026.
What did AHPRA change about telehealth prescribing in October 2025?
The headline change is scope. The Medical Board's revised telehealth guidelines have been in force since 1 September 2023 and have always said that prescribing without a real-time consultation is not good practice. What changed on 7 October 2025 is that AHPRA, on behalf of all 15 National Boards, issued a unified update applying the same position across every regulated health profession, and pointed it directly at "emerging business models focused more on profit than patient safety".
The substantive wording AHPRA adopted is short and quotable. The Boards "do not support" practitioners prescribing for a patient the practitioner "has never consulted, whether face-to-face, via video or telephone". Requests communicated by "text, email or online that do not take place in real time", or based on the patient completing a questionnaire without a formal consultation, are explicitly captured. And the Boards state plainly that "an online chat" is not a synchronous consultation. The same standard now applies to nurse practitioners, pharmacists, dentists and other prescribing professions, not just medical practitioners.
The other change worth noting is the brief AHPRA wording wobble. The initial 7 October release suggested good-practice prescribing required a prior face-to-face consultation. After RACGP and others pointed out this was stricter than the existing Medical Board guidelines, AHPRA revised the wording on 9 October 2025 so that good practice is established "where you've had a face-to-face, video or telephone consultation" with the patient. That is now the operative form. Practices reading old October 7 commentary should rely on the revised wording.
Is questionnaire-only or asynchronous prescribing legal in Australia?
It is not illegal in the criminal-law sense, but it is not good practice, and that exposes the prescriber to significant regulatory, indemnity and professional risk. The two phrases have a precise meaning in this context.
Asynchronous prescribing is any prescribing that happens without the practitioner and patient interacting in real time. A patient fills in a webform, a clinician reviews it at a later time without contacting the patient, and a script is issued. Questionnaire-only prescribing is the most common variant: a structured online intake form, sometimes combined with a photo or self-declared measurement, with no synchronous follow-up.
Under the Medical Board's current telehealth guidelines, "providing healthcare, including prescribing, issuing certificates and referring, via questionnaire-based asynchronous web-based tools in the absence of a real-time patient-doctor consultation is not good practice". AHPRA's October 2025 update reinforces this and extends it to non-medical prescribers. A finding of "not good practice" is the threshold for performance and conduct action under the National Law. It does not require any patient harm or complaint; AHPRA can act on its own monitoring, as it has publicly signalled it now does for high-risk telehealth models.
The practical answer for a practice is therefore: if your service relies on a questionnaire flow with no real-time consult, you are operating outside what AHPRA considers acceptable practice, your indemnity may not respond, and you are visible to the regulator.
What does AHPRA mean by a "real-time consultation"?
Real-time means synchronous: the practitioner and patient are communicating with each other at the same moment, in a back-and-forth conversation. The accepted modalities are face-to-face, video, or telephone. AHPRA's specific carve-out is that "an online chat" (a text-based exchange, even if conducted on a live web platform) does not satisfy the requirement, because it cannot deliver the verbal cues, contemporaneous question-and-answer flow, and clinical observation a synchronous consult depends on.
Three operational implications follow. First, identity verification must happen in the consultation itself, not by uploaded document alone, because the practitioner needs to satisfy themselves the person presenting is the patient on record. Second, the practitioner must form a contemporaneous clinical impression: a video or phone consult must include the kind of history, examination (where possible) and clinical reasoning that supports the prescribing decision. The 2020 tribunal that reprimanded Dr B for inappropriate online prescribing turned on exactly this: failure to take an adequate history, conduct an adequate examination, or order appropriate investigations before prescribing. Third, the consult must be documented to a standard that lets a peer reviewer reconstruct what happened, including the indication for the medicine, the dose, any contraindications considered, and the safety-netting advice given.
The Medical Board has also been explicit that practitioners using telehealth must comply with state and territory legislation including real-time prescription monitoring (where the medicine is monitored) and My Health Record obligations.
Which telehealth services are most exposed in 2026?
AHPRA's October 2025 release named the high-risk territory directly. Weight loss medication (especially the GLP-1 class such as semaglutide and tirzepatide), peptides, medicinal cannabis, and cosmetic injectables and oral cosmetic prescriptions are the categories where questionnaire-only and lightly-supervised business models proliferated through 2023 to 2025 and are now the focus of regulator and indemnity attention.
The structural problem AHPRA flagged is vertically integrated clinics: a single business operating both the telehealth consult and the dispensing pharmacy (and in some cases the product manufacturer), where commercial incentives push toward higher prescribing volumes and lower friction in the consult. The Aesthetic Medical Practitioner coverage and AMA commentary both link the guidance to these models specifically.
The implication for a typical general practice or allied health clinic is less direct but still material. If your practice refers patients to one of these services, or co-locates with one, or employs a contractor who also works for one, you have a touchpoint with the same regulatory issue. Your obligation to refer to safe practitioners (and your continuity-of-care responsibilities when a patient comes back with a prescribed-elsewhere medicine on their list) sit alongside the prescribing clinician's own obligations.
| High-risk service | Why it's flagged | Practical exposure for a general practice |
|---|---|---|
| GLP-1 weight loss medication | Questionnaire intake, no examination, semaglutide and tirzepatide demand | Patient presents with off-label or compounded GLP-1 prescribed elsewhere; medication reconciliation and side-effect management falls on the GP |
| Peptides | Sports and wellness prescribing without therapeutic relationship | MIGA has explicitly excluded indemnity for asynchronous peptide telehealth |
| Medicinal cannabis | High-strength THC volumes, vertically integrated clinic-pharmacy models | Patient on a non-RTPM-compliant or undocumented cannabis script; ongoing care and driving advice issues |
| Cosmetic injectables and oral cosmetic medicines | Async script before in-person nurse-administered procedure | If your practice hosts cosmetic services, the prescribing arrangement must include a real-time consult |
| Online erectile dysfunction, hair loss, sleep | Mature single-issue telehealth model, often questionnaire-only | Patient may present with a chronic on-script medicine the GP did not initiate |
What does "good practice" telehealth actually look like?
The simplest way to operationalise the AHPRA position is a binary check. The table below distils the Medical Board telehealth guidelines and the October 2025 AHPRA update into a side-by-side comparison.
| Element | Good practice (compliant) | Not good practice (AHPRA risk) |
|---|---|---|
| Consultation modality | Face-to-face, video or telephone, in real time | Online questionnaire only; text/email exchange; "online chat" |
| Practitioner-patient relationship | Either pre-existing, or established through the consult itself with full history | None: practitioner has never consulted this patient before issuing the script |
| Identity verification | Confirmed in the consult: matched against ID and existing records where available | Self-declared via webform; no verification step in real time |
| History and examination | Recorded contemporaneously; examination where modality permits | Reliance on patient-completed questionnaire data only |
| Continuity of care | Documented plan for follow-up, GP communication, side-effect monitoring | Single-issue script with no follow-up arrangement |
| Records | Full clinical record supporting the decision, indication, dose rationale | "Name, date, complaint, allergies" only (the failing pattern in the Dr B tribunal) |
| Prescription monitoring | RTPM and My Health Record checked where required | RTPM bypassed; no My Health Record interaction |
| Business model | Independent clinical judgement, no perverse incentives | Vertically integrated clinic-pharmacy, volume-based remuneration |
| Indemnity | Covered by mainstream MDO product | Excluded under MIGA and increasingly other indemnity products |
If a practice can answer "good practice" to every row, it is operating inside the AHPRA-accepted envelope. A single "not good practice" row is enough to put a service inside the active-monitoring zone.
What happens if you breach the AHPRA telehealth guidance?
There are three parallel exposures, and the dollar and reputational cost is dominated by the second and third rather than the first.
Regulatory action under the National Law. AHPRA can investigate a practitioner on its own initiative, on notification from another practitioner, or following a patient complaint. Outcomes range from no further action, through conditions on registration (mandatory education, mentoring, audit) and reprimand, to suspension and cancellation. The Dr B case (reprimand plus education, mentoring and random practice audit) is a representative outcome for a first-time inappropriate prescribing finding without patient harm. AHPRA is also under a mandatory notifications regime, so peers and employers who become aware of clearly substandard practice may have an obligation to notify.
Indemnity refusal. MIGA has confirmed publicly that it will not cover doctors who prescribe medicinal cannabis or peptides via telehealth without an established therapeutic relationship, and that it may not cover completely asynchronous telehealth in general. Other major MDOs are moving in the same direction. An indemnity refusal means the practitioner personally funds the legal defence, any settlement and the regulator-facing costs. For a contested AHPRA matter that can be six-figure exposure before any patient claim.
Reputational and Medicare collateral. AHPRA actions are public. They appear on the practitioner's public register entry. Where the practice also bills Medicare, a finding can trigger separate PSR or Medicare compliance scrutiny, particularly if the prescribing volume looks anomalous against item-numbered consult patterns. The Department of Health, AHPRA, Services Australia and the TGA all share intelligence.
What practices must do before mid-2026
Treat 30 June 2026 as the practical internal review date. Patient and prescribing volumes recover from winter from July, audit risk rises with volume, and the indemnity-year resets for many MDOs in mid-year. The following checklist captures the minimum review every practice should complete.
- Map every telehealth touchpoint in the practice: scheduled video consults, phone consults, after-hours partnerships, contractors who run telehealth side businesses, and any service the practice refers to.
- Confirm in writing with every contractor that they conduct real-time consults (video or phone) before prescribing, that they hold current indemnity covering the modality, and that their indemnity does not carve out telehealth or asynchronous prescribing.
- Review your practice's telehealth workflow document. Identity verification must occur in the consult. Records must capture history, examination where possible, decision rationale, and follow-up plan.
- Reconfirm RTPM workflow for every monitored medicine: which staff check, at which step, and where the check is documented. The Medical Board telehealth guidelines explicitly require it; relying on memory is not a defence.
- Update your patient information sheet and website to set clear expectations about how telehealth works at your practice (real-time consult, identity verification, what is and is not prescribable).
- If your practice hosts or co-locates with cosmetic, weight management, or medicinal cannabis services, audit the prescribing arrangement. A questionnaire flow that ends with a real-person procedure does not satisfy the AHPRA test; the script itself needs a real-time consult.
- Review continuity-of-care patterns. Patients arriving on externally-prescribed weight loss, peptide, cannabis or cosmetic medication need a documented reconciliation and a plan, not a silent acceptance onto the medicines list.
- Brief reception and nursing staff on the new "no online chat as a consult" position, because patients will ask about webform-only services and expect a clear answer.
- Cross-check that your telehealth Medicare billing is aligned: the Medicare telehealth rules (12-month rule, MyMedicare exemption, 80/20 and 30/20) sit alongside the AHPRA prescribing rules. A consult that breaches Medicare and a script that breaches AHPRA is a compounded exposure.
- Schedule a quarterly review during the rest of 2026 to capture any further AHPRA wording updates and any new state or territory RTPM expansions.
For practices already registered under MyMedicare, the continuity-of-care obligations dovetail with the AHPRA position naturally: the same patient-relationship logic that justifies MyMedicare registration is what AHPRA expects to see behind a telehealth script.
Frequently Asked Questions
What did AHPRA change about telehealth prescribing in October 2025?
On 7 October 2025, AHPRA issued updated guidance on behalf of all 15 National Boards, extending the Medical Board's existing position that prescribing without a real-time consultation is not good practice across every regulated profession. The guidance explicitly captures questionnaire-only and asynchronous prescribing, including text, email and "online chat" exchanges. AHPRA briefly suggested a face-to-face consult was required and then revised the wording on 9 October 2025 so that face-to-face, video or telephone all qualify.
Is asynchronous or questionnaire-only prescribing allowed in Australia?
It is not unlawful, but it is not good practice under the Medical Board telehealth guidelines and the October 2025 AHPRA update. A finding of not good practice supports performance and conduct action under the National Law without any patient complaint being required. Major medical defence organisations including MIGA are now refusing to indemnify doctors for completely asynchronous prescribing, particularly for medicinal cannabis and peptides. In practical terms, the model is no longer commercially viable for a practitioner who wants to keep their registration and indemnity.
Can you prescribe weight loss medication online without a consultation?
Not without a real-time consultation. AHPRA flagged weight loss medication, specifically GLP-1 agonists such as semaglutide and tirzepatide, as one of the high-risk categories driving the October 2025 update. A practitioner must conduct a synchronous consult (face-to-face, video or telephone), take a contemporaneous history, document the clinical reasoning, and establish a follow-up plan. A questionnaire intake leading directly to a script does not meet the AHPRA standard, and indemnity insurers are increasingly refusing cover for this model.
What counts as a "real-time consultation" for telehealth prescribing?
A real-time (synchronous) consultation is a face-to-face, video or telephone interaction where the practitioner and patient communicate in real time. AHPRA has expressly stated that an "online chat" (a text-based exchange, even on a live platform) is not a synchronous consultation. The consult must include identity verification, history-taking, examination where the modality permits, and a contemporaneously documented clinical record. The same standard applies whether the consultation is initiated by the patient or the practitioner.
How does this affect a practice that refers to or co-locates with online prescribing services?
A practice that refers patients to an asynchronous-prescribing telehealth service inherits exposure on two fronts. First, the referring practitioner has a professional obligation to refer to safe practice, which is harder to defend if the destination service uses a questionnaire-only model. Second, when the patient returns to the practice with an externally-prescribed medicine on their list, the practice picks up continuity-of-care responsibilities, including medication reconciliation, side-effect monitoring and any mandatory notification obligation if the external prescribing pattern is clearly substandard. Co-located cosmetic and weight management arrangements need the prescribing step itself to include a real-time consult.
Will AHPRA actually enforce the new guidance, or is it just signalling?
AHPRA has publicly said it monitors high-risk telehealth and prescribing business models proactively, without waiting for patient complaints. Tribunal cases such as the 2020 reprimand of a GP for inappropriate online prescribing confirm regulators were prepared to act under the older framework, and the October 2025 update strengthens the standard. With indemnity insurers withdrawing cover from the highest-risk models, the practical enforcement is happening through three parallel channels (regulator, insurer, public register), not just AHPRA investigations.
What should our practice do before 30 June 2026?
At minimum: map every telehealth touchpoint including contractor arrangements; confirm real-time consult workflows and indemnity coverage in writing; update the practice's telehealth workflow document to require identity verification, contemporaneous records and a follow-up plan; reconfirm RTPM and My Health Record steps for monitored medicines; audit any co-located cosmetic, weight management or medicinal cannabis arrangements; brief reception and nursing staff on the "no online chat as a consult" position; and align the telehealth workflow with your Medicare telehealth billing rules so a single consult satisfies both AHPRA and Medicare.