Primary Care Services Via Remote or Virtual Means

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Ministerial Order (M.O.) 2024-016, dated August 23, 2024, was enacted under the authority of the Minister of Health of Quebec. This order, titled “Regulation respecting health services and social services that may be provided and activities that may be conducted from a distance,” is part of the Act respecting health services and social services (S-4.2) and the Act to increase the supply of primary care services and to improve the management of that supply (2022, chapter 16). The primary aim of this regulation is to expand the availability of primary care services through remote or virtual means while ensuring that the management and quality of these services are upheld.

The regulation focuses on several key aspects: ensuring the quality of remote services, defining which services can be provided virtually, and outlining the responsibilities of healthcare professionals in delivering these services.

Key provisions of the regulation outline several conditions that must be met for health and social services to be provided remotely. First, the recipient must give informed consent before receiving remote services, ensuring they are aware of the limitations and implications of virtual care. Second, the nature of the service must be appropriate for remote delivery, meaning that services requiring physical examinations or direct support cannot be conducted remotely. Institutions must also have a contingency plan in place in case of technological issues during the provision of these services, ensuring the continuity of care. Additionally, patients must be offered an in-person follow-up option if further care or monitoring is needed. The regulation also allows for remote activities organized by healthcare institutions, provided they meet the same conditions as remote service delivery.

In terms of informed consent and confidentiality, before obtaining consent, healthcare providers are required to inform patients about certain factors. These include the inherent limitations of remote services, such as the potential inability to conduct thorough physical examinations, the risks associated with the communication methods used (particularly concerning the confidentiality of personal information), and the options for in-person follow-up, if applicable. Providers must also inform patients if communications will be recorded.

The regulation addresses the responsibilities of health professionals working in specialized medical centers or private health facilities. If follow-up services are required, they must be provided by the same professional who delivered the remote care or another qualified professional from the same practice or affiliated institution.

By establishing clear guidelines for the provision of remote care, it aims to increase the accessibility of primary care services while maintaining high standards of quality and patient safety.

Quebec (2024-016) September 11, 2024