On 1 September 2023, the Medical Board of Australia’s revised guidelines, Telehealth consultations with patients, took effect. The headline change was blunt: prescribing for a patient without a real-time consultation, whether in person, by video or by phone, is not good practice and is not supported by the Board. That puts “tick-box” questionnaire prescribing, where a doctor never speaks to the patient, outside what the Board considers good medical practice.
These are practice guidelines, not advertising rules. But they matter a great deal for marketing, because the way a telehealth service is promoted describes the patient journey. If your website, ads or app promise a script without a conversation with a doctor, the marketing itself becomes evidence of a model the Board does not support. These guidelines remain current. Ahpra and the National Boards later updated their cross-profession telehealth guidance on 7 October 2025 (see our article on the updated Ahpra telehealth guidance and single-product prescribing), and the TGA published new guidance on advertising prescription medicines on 18 June 2026, which deals directly with how telehealth services are promoted.
What changed
The Medical Board announced the revised guidelines on 31 May 2023, after consulting the community and the profession, and set an effective date of 1 September 2023. The Board said there were approximately 770 submissions to its consultation.
The new guidelines replaced two older documents: the Guidelines for technology-based patient consultations, issued on 16 January 2012, and the Information sheet: Inter-jurisdictional technology based patient consultations, issued on 15 August 2013. They were developed under section 39 of the Health Practitioner Regulation National Law, and the Board says they will generally be reviewed at least every five years.
The Board’s announcement summarised three main points:
- Telehealth consultations continue as an important feature of healthcare in Australia.
- Real-time doctor and patient consultations remain key to safe prescribing.
- Prescribing through questionnaire-based, asynchronous web tools, without a real-time consultation, is not considered good practice.
The Board was equally clear about what it did not change. Patients can consult a doctor for the first time by telehealth, and doctors can issue new and repeat prescriptions as part of a telehealth consultation. The Board does not expect a patient to have had an in-person appointment before a telehealth appointment.
Who it applies to
The guidelines apply to registered medical practitioners who consult with patients by telehealth. In the guidelines, “telehealth consultations” means consultations that use technology as an alternative to an in-person consultation. That can include video, internet or telephone consultations, transmitting digital images or data, and prescribing medicines.
Some activities are outside the definition: using technology during an in-person consultation, one doctor giving an opinion to another, remote patient monitoring and tele-education.
In practice, the people who need to understand these guidelines include:
- GPs and specialists who offer telehealth appointments alongside in-person care
- doctors working for telehealth-only services and online prescribing platforms
- practice owners and managers who design booking flows and patient intake
- marketing teams and agencies who describe those services to the public.
Non-medical business owners are not directly bound by Medical Board guidelines, but the doctors working in their services are, and those doctors carry the professional risk if the service model does not meet the Board’s expectations.
What the rules require
A real-time consultation before prescribing
The central requirement sits in the section headed “Prescribing or providing healthcare if you have never had a real-time consultation with the patient”. The Board says prescribing or providing healthcare without a real-time direct consultation, whether in person, via video or telephone, is “not good practice and is not supported by the Board”.
The guidelines spell out what this covers: asynchronous requests for medication communicated by text, email, live chat or online, that do not happen within a real-time continuous consultation and are based on the patient completing a health questionnaire, when the practitioner has never spoken with the patient.
Being able to justify any exception
The guidelines do not create an absolute ban. A practitioner who prescribes in those circumstances must be able to explain how the prescribing and management of the patient was appropriate and necessary. The Board also recognises that a patient’s usual medical practitioner, or another practitioner with access to the patient’s clinical record, may appropriately prescribe without a consultation in certain circumstances.
The same standard of care as in person
The Board expects the standard of care in a telehealth consultation to be safe and, as far as possible, to meet the same standards as an in-person consultation. It says that when practical, video is preferable to telephone, and that telehealth is generally most appropriate within a continuing clinical relationship that also involves in-person care. The guidelines do not prevent or discourage one-off telehealth consultations.
Before, during and after the consultation
The guidelines list practical expectations, including:
- Before: a private consultation space, secure technology fit for clinical purpose, secure access to records, and a plan if the technology fails. Patients should know the alternatives to telehealth, have the billing arrangements explained and give financial consent, and be told they may need to be seen in person.
- During: telling the patient who you are, your specialty if relevant, your principal place of practice and your role in their care; confirming the patient’s identity; obtaining informed consent; and continuously assessing whether telehealth is still appropriate.
- Prescribing: complying with state and territory prescribing laws in both the prescriber’s and the patient’s jurisdictions, including real-time prescription monitoring and My Health Record, and putting contact details on prescriptions.
- After: handover and follow-up where needed, informing the patient’s usual GP with consent, and keeping records that include the technology used and any technical issues.
Information from third parties
Doctors must accept responsibility for evaluating information used in assessment and treatment, whatever its source. That includes histories or examinations gathered by a third party. For platforms that use intake staff, nurses or forms to collect information before a doctor is involved, this point matters: the doctor still owns the clinical judgement.
International telehealth
If you consult with patients who are in Australia, the Board expects you to be registered with it and to meet its registration standards, wherever you are located. If you are in Australia and consulting patients overseas, you should check whether the regulator in the patient’s country requires registration.
What it means for your marketing
The guidelines contain no specific advertising rules. The marketing implications below follow from the practice requirements, and from the general rule that advertising must not be false, misleading or deceptive. If marketing describes a pathway that the Board does not support, it can draw attention to the practitioners involved.
Website and booking flow
Your website is where the patient journey is most visible. Review it for any wording that suggests a prescription can be obtained without speaking to a doctor, such as “no consult needed”, “skip the appointment” or “fill in a form and get your script”. Also review the booking flow itself. If a patient can complete a questionnaire and receive a prescription without a live consultation, the problem is the model, and no amount of copy editing fixes it.
What you can say, consistent with the guidelines, is that patients can see a doctor by video or phone, including for a first appointment, and that the doctor will decide in the consultation what care is appropriate. Being clear that a doctor may recommend an in-person visit is consistent with the guidelines’ expectation that patients are told this.
Paid search and social ads
Short ad formats encourage shortcuts. Phrases like “script in minutes” or “instant prescriptions” imply an outcome before any assessment. Separately, naming specific prescription-only medicines in public ads raises a different problem under therapeutic goods law, which is discussed below. Ads should promote the consultation, not a prescription.
Google Business Profile and reviews
Telehealth services often have a Google Business Profile that describes services and attracts reviews. Keep the service description consistent with a consultation-based model. Under the National Law, registered health practitioners cannot use testimonials in advertising, so do not republish reviews about prescribing speed or ease on your website or ads.
Email, SMS and app notifications
Reminder messages about repeat prescriptions are common. Make sure they invite the patient to book a consultation rather than suggesting a repeat will be issued automatically. If your service relies on the “usual practitioner” exception for some repeats, that is a clinical decision for the treating doctor, not a marketing promise.
Partnerships and affiliate marketing
If a third party drives patients to your telehealth service, their promotion reflects on your practitioners. Brief partners on how the service works and what they must not claim.
Common mistakes we see
- Copy that outlives the model. A service changes its clinical model to include real-time consultations, but old landing pages still say “no appointment required”.
- Calling a chat a consultation. Describing a live chat or messaging exchange as a consultation. The Board’s guidelines list live chat among the asynchronous requests it does not support, and Ahpra’s later guidance says the Boards do not consider an online chat to be a synchronous consultation.
- Promising a result. “Get your prescription today” presumes the doctor’s decision before the consultation has happened.
- Speed as the main selling point. Heavy emphasis on how quickly a script arrives, rather than on access to a doctor.
- Hidden billing. The guidelines expect billing arrangements to be explained before the consultation. Marketing that hides fees until after intake works against that.
- Naming medicines. Listing prescription-only medicines by name on public pages, which raises separate TGA advertising issues.
A practical checklist
- Map your patient journey from ad click to prescription and confirm a real-time consultation (in person, video or phone) occurs before any prescribing for new patients.
- Remove wording such as “no consult”, “no appointment”, “questionnaire only”, “instant script” or similar from websites, ads, app store listings and social profiles.
- Check that any questionnaire is described as intake information for the doctor, not as the assessment itself.
- Make sure the website explains that the doctor may recommend an in-person consultation.
- Explain fees, Medicare rebate eligibility and any gap before the consultation.
- Show the practitioner’s name and, where relevant, specialty and principal place of practice in the consultation experience.
- Rewrite repeat prescription reminders so they invite a consultation rather than promising a repeat.
- Remove named prescription-only medicines from public marketing.
- Brief affiliates, influencers and partners in writing on what they can and cannot say.
- Review legacy pages, blog posts and paid ad history, not just the homepage.
How this fits with other rules
Ahpra advertising guidelines. The National Law and Ahpra’s Guidelines for advertising a regulated health service prohibit false, misleading or deceptive advertising and testimonials, among other things. Advertising that misdescribes how a telehealth service works can fall foul of these rules.
Ahpra’s cross-profession telehealth guidance. Ahpra and the National Boards publish guidance for all registered practitioners who use telehealth. It was updated on 7 October 2025 and is consistent with the Medical Board’s guidelines. It applies the same real-time consultation expectation to all prescribers and adds that the individual practitioner, not their employer or business, is responsible for care provided by telehealth.
TGA advertising rules. Advertising prescription-only medicines to the public is prohibited under the Therapeutic Goods Act 1989, with limited exceptions. This is separate from the Medical Board’s guidelines. The TGA’s guidance published on 18 June 2026 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 of those medicines.
Medicare and privacy. The guidelines note that other rules, including Medicare billing and privacy law, also apply to telehealth and are not covered in the guidelines themselves.
Frequently asked questions
Can a new patient’s first appointment be by telehealth?
Yes. The Board says patients can consult a doctor for the first time using telehealth, and it does not expect an in-person appointment first. You can market first-time telehealth appointments, provided the consultation happens in real time.
Can a doctor prescribe in a telehealth consultation?
Yes. The guidelines allow new and repeat prescriptions as part of a telehealth consultation. The issue is prescribing without any real-time consultation, not prescribing by telehealth.
Is a phone call enough, or does it need to be video?
The guidelines treat in-person, video and telephone consultations as real-time consultations. The Board says video is preferable to telephone when practical.
Are online questionnaires banned?
Not as such. Questionnaires can be used to gather information. What the Board does not support is prescribing based on a questionnaire when the practitioner has never spoken with the patient. Any practitioner who does this must be able to explain why it was appropriate and necessary.
Can a patient’s regular GP issue a repeat without a consultation?
The Board recognises that a patient’s usual practitioner, or another practitioner with access to their clinical record, may appropriately prescribe without a consultation in certain circumstances. This is a clinical judgement, so it should not be advertised as something every patient will receive.
Do these guidelines apply to nurse practitioners and other prescribers?
The Medical Board’s guidelines apply to medical practitioners. Ahpra and the National Boards publish separate telehealth guidance that applies the same expectations to all registered practitioners, including other prescribers.
Related articles
- TGA guidance on advertising medicinal cannabis and later enforcement
- Compounded GLP-1 restrictions and weight-loss advertising enforcement
- Ahpra’s 2025 telehealth guidance and single-product prescribing
- Peptides and compounded medicines: Ahpra and TGA guidance and action
Need a hand?
If you run or market a telehealth service, it helps to have someone check the whole patient journey, not just the homepage. Our AHPRA compliance audit reviews websites, ads and booking flows against the published rules, and our compliant content service can rewrite service pages so they describe consultations accurately. GPs offering telehealth alongside in-person care may also find our general practice page useful.
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.