The College of Naturopaths of Ontario

This is a guest post by Dr. Mary-Ellen McKenna, ND (Inactive) the College's Regulatory Education Specialist

The public is able to access virtually everything online through the convenience of their computer, tablet or phone. More and more, patients are expecting to be able to access naturopathic care online. The challenge for Members is whether they can provide the services patients are looking for in ways that meet patient expectations, while adhering to the regulations and standards of practice set by the College.

Members are feeling the pressure to provide online services and information to patients as a way to build their practice and earn a living. However, as a regulated health professional they are responsible for ensuring their patients receive the best care possible. A patient's interest in the convenience of online care does not override the Member's responsibility to ensure that every patient receives the same level of care and consideration as they would during an in office visit.

In all practice settings, whether in person or online, the Member is required to apply the standards set by the College. For example, the naturopathic doctor-patient relationship must be established, informed consent must be obtained, and proper records kept.

When considering the option of an online visit there are specific issues to keep in mind.

The Needs and Condition of Each Patient

Members are to use their professional judgment to consider the circumstances of each patient as well as each visit and decide if providing care online is in the patient's best interest. The patient's condition and their individual needs must be considered in conjunction with the Member's ability to conduct a full assessment and gather all the information needed to make a diagnosis, and then provide the most appropriate treatment. The convenience and time-effectiveness of conducting online consultations should not be the primary deciding factor.

Fees and Billing

Members may charge fees specific to online visits, provided patients are informed of the costs, and all billing processes are compliant with the Standard of Practice for Fees and Billing.

The College is aware that there are health care clinics the provide "concierge medicine". The fee structure associated with this health care model requires patients to pay a monthly or annual fee, sometimes referred to as a membership fee, for access to a package of services. Members are reminded that they are not allowed to charge a block fee which is defined as a flat fee charged for a predetermined set of services or unlimited services.

Legal Authority

When providing care to a patient who is located in another province, territory or country, the Member must comply with the legistlative/regulatory requirements of that jurisdiction. This may require that the ND holds the appropriate licence or registration with the naturopathic or medical regulatory authority of the jurisdiction in which they are practising via telemedicine. In a province, territory or country where NDs are unregulated, the legislation of that jurisdiction may make it unlawful for an ND to provide naturopathic care to the patient.

It is the responsibility of the ND to ensure they are aware of the laws of the jurisdiction where the patient is located and to abide by them as well as the regulations and standards of the College.

Patient Privacy

The Member always has the responsibility to ensure that a patient's health information is kept private and confidential in accordance with the Personal Health Information Protection Act, 2004 (PHIPA). This includes ensuring that reasonable security protocols are in place with respect to the technology being used. The use of cell phones and applications (apps) may allow for accidental access to the patient's information by unauthorized third parties. The physical setting of the patient and whether they are in a private place rather than in a public setting should be considered. While the patient may consent to the use of such technology, the ND still has the requirement to ensure privacy. The Information and Privacy Commissioner of Ontario can provide information on the technologies and accredited networks that meet the necessary security standards.

Insurance Coverage

Check with your insurance provider to ensure whether you have proper coverage for conducting visits with patients located outside Ontario. Consider the possibility that someone living outside the province may choose to initiate legal proceedings for alleged malpractice in their province, territory or country, particularly if the foreign jurisdiction allows for the potential of higher damages to be awarded as compared to what may be allowed in Ontario.