Ahpra’s 2025 telehealth guidance and single-product prescribing

Ahpra updated its telehealth guidance on 7 October 2025, after Health Ministers flagged single-product prescribing. What it means for marketing.

7 October 202511 min read

On 7 October 2025, Ahpra and the National Boards updated their telehealth and virtual care guidance for all registered practitioners. The update responded to concerns about unethical practice and to business models that Ahpra said were focused more on profit than patient safety. It confirmed that good practice means only prescribing where there has been a face-to-face, video or telephone consultation, and that the practitioner, not the employer, is responsible for care delivered by telehealth.

A few weeks earlier, at their 12 September 2025 meeting, Health Ministers had put single-product telehealth prescribing on the national agenda. Together these developments matter for anyone marketing a telehealth-only or single-treatment service. Since then, Ahpra has published guidance on prescribing off-label, unapproved or compounded medicines (16 September 2026) and interim conflict of interest guidance (September 2026), and the TGA published guidance on advertising prescription medicines to the public on 18 June 2026. These build on, rather than replace, the October 2025 guidance (see our articles on those topics).

What changed

Ahpra’s updated telehealth guidance (7 October 2025)

Ahpra’s news release said the revised guidance ensures proper consultation and practitioner accountability, reflects concerns about unethical practice and emerging business models, and adds new case studies on common telehealth pitfalls. It said the guidance expands advice for telehealth prescribers, highlighting poor practice where prescribing relies on text, email or online questionnaires rather than a face-to-face, video or telephone consultation.

The release also said:

the guidance is consistent with the Medical Board of Australia’s guidelines, Telehealth consultations with patients, and confirms the same expectations apply to all practitioners
any healthcare provided through telehealth is the practitioner’s responsibility and not the employer’s
practitioners in telehealth-only clinics, particularly those focused on single treatments or medicines, are encouraged to review the clinical governance framework so care is not compromised by commercial gain or convenience
Board case studies identify common mistakes, such as prescribing in an initial telehealth consultation, or choosing telehealth when a face-to-face consultation is needed.

Ahpra reported 586 telehealth-related notifications in 2024-25. The release gives no separate effective date; the guidance applies from publication.

Health Ministers’ decisions (12 September 2025)

The Health Ministers Meeting communique, published on 26 September 2025, recorded several decisions relevant to telehealth business models:

Cosmetic injectables: Ministers discussed regulatory challenges, including inconsistent regulation, cross-border and telehealth workarounds, and non-compliant practices. They noted Ahpra’s new guidelines on non-surgical cosmetic practice and nurse prescribing. The Department of Health, Disability and Ageing, including the TGA, will continue reviewing single-product telehealth prescribing and report back on any further nationally coordinated action needed.
Medicinal cannabis: Ministers discussed the rise in prescribing, agreed to consider further work on governance and oversight to address inappropriate prescribing, and asked the TGA to report back on the outcomes of its review. They asked the Department for an update on actions from a national telehealth prescribing workshop held in May 2025, and asked the Medical Board to report on its approach to complaints about over-prescribing of medicinal cannabis through telehealth business models.

The communique did not create a new binding rule. Later Health Ministers’ communiques we checked, up to September 2026, did not contain advertising-specific decisions on this topic.

Who it applies to

Ahpra’s guidance applies to all registered health practitioners who use telehealth, across all professions. It explains how existing obligations in each National Board’s code of conduct apply to telehealth. Medical practitioners also have the Medical Board’s own telehealth guidelines.

The guidance is particularly relevant to:

practitioners working in telehealth-only clinics and single-treatment services, such as weight-loss, men’s and women’s health, medicinal cannabis and cosmetic injectables
nurse practitioners and other prescribers working through online platforms
clinic owners and employers, including those who are not registered practitioners, because their practitioners carry the professional responsibility
marketers who design intake flows, landing pages and ads for these services.

What the rules require

Telehealth only where it is safe and suitable

The guidance says practitioners can use telehealth if they are appropriately skilled and competent, it is safe and clinically appropriate for the service, and it is suitable for the patient. National Boards have the same expectations of practitioners using telehealth as for face-to-face care.

Prescribing needs a real consultation

The guidance says National Boards do not support or consider it good practice to prescribe for a patient the practitioner has never consulted, whether face-to-face, by video or by phone. This includes requests by text, email or online that do not happen in real time, or that are based on a health questionnaire where the practitioner has not formally consulted with the patient. It adds that the Boards do not consider an online chat to be a synchronous, real-time consultation.

A practitioner who prescribes in those circumstances may be asked to explain how the prescribing and management was appropriate and necessary, and how they assessed that the patient was a suitable candidate.

The practitioner is responsible, not the business

The guidance states that the individual practitioner, not their employer or business, is responsible for healthcare provided by telehealth. Practitioners in telehealth delivery businesses should assess the framework for delivery of care to ensure it is not being compromised by commercial considerations or practitioner convenience.

Transparency about conflicts of interest

Practitioners should be transparent with patients and prospective patients about any conflict of interest, such as a financial interest in a medicine, product or service they endorse for financial compensation or sell.

Good practice in the consultation

The news release lists good telehealth practices, including sharing information in a way the patient can understand, getting the medical history needed for a diagnosis, gaining informed consent (including for AI scribes), telling patients when telehealth may not meet their needs, and confirming the patient’s identity. The guidance also asks practitioners to consider carefully any use of technology, such as AI or chatbots, to simulate patient conversations about care in place of conversations with a practitioner.

Prescription monitoring and cross-border rules

Prescribers should comply with the prescribing laws of each relevant state or territory and, when appropriate, use monitoring services such as real-time prescription monitoring, My Health Record and the Prescription Shopping Programme.

What it means for your marketing

The guidance does not contain advertising rules. The marketing implications below follow from the practice expectations and from the advertising rules that already apply.

Website and intake flow

If the patient journey on your site ends in a prescription without a real-time consultation, the guidance says that is not good practice. Remove “no call needed”, “no appointment” and “questionnaire only” language, and make sure the flow itself includes a face-to-face, video or phone consultation before prescribing. Do not describe a chat as a consultation.

Avoid promising an outcome before assessment. “Get your treatment plan today” or “approved in minutes” presumes a decision only the practitioner can make, and case studies identify prescribing in an initial telehealth consultation as a common mistake.

Chatbots and automated tools

If your site uses a chatbot to triage or advise, keep it clearly administrative. Ahpra’s guidance asks practitioners to think carefully about technology that stands in for conversations with a practitioner. The TGA’s current guidance separately says an automated system that suggests a prescription can be issued for certain conditions is likely to be advertising prescription medicines.

Paid ads and landing pages

Single-product services often build their whole brand around one medicine. The TGA’s guidance of 18 June 2026 says health services, including telehealth, that present themselves as services for prescribing or supplying specific prescription medicines risk unlawfully promoting those medicines. Ads and landing pages should promote consultations for the conditions you assess.

Practitioner profiles

Because the practitioner carries responsibility, practitioners should know how they are presented. Check that profile pages are accurate and that practitioners are not shown endorsing products, which raises both conflict of interest and testimonial issues.

Disclosure of conflicts

A footer note saying the business supplies the medicines it prescribes is not the same as disclosure to the patient. Ahpra’s later guidance, published in September 2026, says declaring a conflict on a website, in advertising or on social media is not sufficient disclosure.

Email, SMS and retention campaigns

Renewal reminders and subscription messaging should invite a consultation, not promise continued supply. Mass communications about a prescription medicine are unlikely to be exempt from the TGA’s advertising rules.

Common mistakes we see

Funnels built for conversion, not consultation. Multi-step quizzes that end at a checkout, with a practitioner review happening in the background.
Presenting a chat as a consultation. The guidance says the Boards do not treat an online chat as a real-time consultation.
Brand names built around a medicine. Business names, domains or logos that refer to a prescription medicine or class of medicines.
Subscription language. “Your monthly supply, delivered” suggests ongoing prescribing regardless of review.
Website-only conflict disclaimers. Treating a line in the terms and conditions as disclosure.
Leaving it to the platform. Practitioners assuming the business owner is responsible for how care is delivered and promoted.

A practical checklist

Confirm that every new patient pathway includes a face-to-face, video or telephone consultation before any prescribing.
Remove references to questionnaire-only, chat-based or “no appointment” prescribing from all public content.
Check that intake forms are described as information for the practitioner, not as the assessment.
Make sure the site tells patients telehealth may not suit their needs and an in-person visit may be recommended.
Review chatbots and automated tools so they do not suggest prescriptions.
Remove named prescription medicines, class terms and related imagery from ads, landing pages, brand assets and booking systems.
Check practitioner profiles for accuracy and remove any product endorsements.
Set up conflict of interest disclosure in the consultation itself, not only on the website.
Rewrite renewal and subscription messaging so it invites review by a practitioner.
Give practitioners a copy of the marketing that describes their services, and ask them to confirm it is accurate.

How this fits with other rules

Medical Board telehealth guidelines. In force since 1 September 2023, they say prescribing without a real-time consultation is not good practice and is not supported by the Board. Ahpra’s guidance is consistent with them and extends the same expectation to all professions.

Ahpra medicinal cannabis guidance (9 July 2025). It flags brief telehealth consultations and coaching questionnaires as poor practice, and warns of an inherent conflict of interest in organisations that only prescribe and dispense a single medicine.

Ahpra advertising guidelines and the National Law. Advertising must not be false, misleading or deceptive and must not use testimonials. Under section 136 of the National Law, anyone, registered or not, who directs or incites a practitioner to engage in unprofessional conduct commits an offence, as Ahpra’s September 2026 conflict of interest guidance reminds employers.

TGA advertising rules. Advertising prescription medicines to the public is prohibited under the Therapeutic Goods Act 1989. The TGA’s health services guidance says that promoting a telehealth service as a way to obtain particular prescription medicines, or a class of them, is likely to be prohibited advertising.

Frequently asked questions

Is prescribing in a first telehealth consultation banned?

No. The Medical Board allows new and repeat prescriptions within a telehealth consultation, including a first consultation. Ahpra’s case studies identify prescribing in an initial telehealth consultation as a common mistake, which means practitioners need to be confident telehealth was suitable and the assessment was adequate. Marketing should not suggest that a first consultation will end in a prescription.

Does a phone call count as a consultation?

Yes. The guidance refers to face-to-face, video or telephone consultations. An online chat does not count as a real-time consultation.

We are a telehealth business, not a practitioner. Does this apply to us?

The guidance applies to registered practitioners, and it says they, not the employer, are responsible for the care. Business owners should note the section 136 offence for directing or inciting unprofessional conduct, and that TGA advertising law applies to anyone who advertises.

Did Health Ministers ban single-product telehealth?

No. In September 2025 they asked the Department, including the TGA, to continue reviewing single-product telehealth prescribing and report back on any further national action. No new binding rule came from that meeting.

Is a conflict of interest statement on our website enough?

No. Ahpra’s guidance published in September 2026 says declaring a conflict on a website, in advertising or on social media is not sufficient disclosure. Disclosure needs to happen with the patient.

Need a hand?

Telehealth services change their funnels often, and older pages linger. Our AHPRA compliance audit looks at the full patient journey, from ad to booking, and our TGA advertising compliance review covers how medicines are, or are not, referenced. For cosmetic and injectables businesses, our cosmetic clinics page explains how we work with that sector.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.