The Telemedicine Practice Guidelines, issued in 2020 by the Ministry of Health and Family Welfare, are the legal basis on which registered medical practitioners may consult patients remotely in India. Only physicians registered with the National Medical Commission or a State Medical Council may practise under them, which means the first thing a platform must do is verify registration rather than accept a claimed qualification.
Three modes of communication are permitted — audio, video and text — and the guidelines are unusually permissive about the technology, listing telephone, video call, devices over LAN or WAN, internet, mobile and landline, and even WhatsApp and Facebook Messenger. That breadth is useful in a country where connectivity varies, and it is also the source of the constraint that matters most for product design.
That constraint is prescribing. Three categories govern what may be prescribed remotely. List O covers over-the-counter medicines and may be prescribed on a first consultation. List A covers relatively safe drugs and may be prescribed on a first consultation only where it was conducted by video. List B is restricted to follow-up consultations. Schedule X drugs and narcotic substances may not be prescribed remotely at all.
Read that again as a software requirement. The mode of the consultation and whether it is a first or follow-up encounter together determine which formulary is available to the prescribing doctor. A product that lets a doctor type any drug into a free-text field has pushed a regulatory decision onto a clinician working at speed, and it has no record of the basis on which the decision was made. The correct design constrains the picker by mode and encounter type, and records both alongside the prescription.
Record keeping is required and the guidelines put the obligation on the physician rather than on the platform. In practice the platform is where the records live, which makes it the platform's problem regardless of where the duty formally sits. That means retaining the consultation record, the mode used, the prescription issued, and enough of the interaction to reconstruct what happened — for a retention period that outlasts any dispute, and in a form that a medical council would accept.
The guidelines recommend platforms that ensure privacy, security and accessibility without assigning specific compliance responsibilities to technology providers. That gap is not comfort; it is why the obligations that do bite come from elsewhere — DPDP on the personal data, which for health information is particularly sensitive, and ABDM if the client wants to participate in the national health stack. A telemedicine product designed only against the 2020 guidelines has satisfied the smallest of the three rulebooks it operates under.
