As the government reviews subordinate regulations for the telemedicine-related medical law set to take effect in December, industry players are demanding the formation of a separate consultative body and science-based institutionalization rooted in field demand. Critics point out that the opinions of companies mediating telemedicine services are being fundamentally restricted in the discussion process, raising concerns that policies disconnected from reality may be created.
The Korea Telemedicine Industry Council (KTIC), a group of telemedicine platform companies, issued a statement on Nov. 20 saying, "Telemedicine policy should not be designed as a compromise of interests among healthcare professions, but in a way that fully reflects the opinions of entities that possess actual field data."
Earlier this month, on Nov. 7, KTIC sent an official letter to the Ministry of Health and Welfare (MOHW) regarding the subordinate regulations containing the telemedicine institutionalization plan, requesting the formation of an industry consultative body. On Nov. 16, it submitted a formal opinion paper on the establishment of the subordinate regulations. KTIC has repeatedly raised its voice ahead of telemedicine's formal institutionalization in December, driven by a sense of crisis that the government is continuing substantive consultations only with medical and pharmaceutical professional organizations while excluding the industry.
A representative example is the government's review, through the subordinate regulations, of limiting the prescription period for first-visit patients to seven days and restricting prescriptions of some non-reimbursable drugs including hair loss treatments.
KTIC argued, "Of approximately 15 million telemedicine cases conducted over the past six years, the overwhelming majority were carried out through mediation platforms." It added, "Mediation platforms are the only entities that hold empirical data—including the needs of citizens using telemedicine and the field experience of participating doctors and pharmacists—and that gather and represent those voices." The council contended that policies created while excluding mediation platforms will inevitably produce regulations detached from the field.
KTIC also viewed the regulation of telemedicine for first-visit patients as a measure that reduces public access to healthcare. Administratively, about 80% of patients using telemedicine are classified as first visits, but 60% of those represent demand for continuous management of already-diagnosed conditions such as chronic illnesses like hypertension and diabetes, skin conditions including atopy and acne, and hair loss. KTIC said, "These cases are counted as first visits simply because the hospitals patients previously attended are not registered on platforms or do not provide telemedicine services, when in reality they are closer to continuous management of previously diagnosed conditions." It warned, "If prescription days are uniformly limited to seven days under such circumstances, more than 60% of platform-using patients will effectively be unable to use telemedicine." According to KTIC, 73.0% of hypertension patients and 95.1% of hair loss patients received prescriptions of 30 to 90 days, and patients receiving prescriptions of more than seven days account for over 60% of the total.
The industry also has significant concerns about the move to restrict telemedicine prescriptions of non-reimbursable drugs such as hair loss medications. KTIC said, "Conditions such as hair loss have characteristics where the effects are rapidly lost when treatment is discontinued, requiring continuous medication." It pointed out, "Replacing the professional prescription judgment made by doctors through examination and consultation with administrative standards will not only deprive many citizens of the right to medical access, but may also undermine continuity of patient treatment." It argued that even based on MOHW's announcement that there were only five medical incidents among 36.61 million consultations conducted during the period of provisional telemedicine authorization, there is no reason to strengthen regulations on safety grounds. It also cited as evidence that short-term conditions such as colds mostly receive prescriptions of seven days or less, while internal medicine conditions are prescribed variously from under seven days to within 90 days depending on patient condition.
The council emphasized, "Uniform regulation may rather limit judgment in medical settings," adding, "The official participation of mediation platforms must be guaranteed, and an opinion-gathering structure that can reflect the data of patients and medical professionals must be established."
