Challenges Remain Despite Ban on Initial Consultations in Internet Hospitals

By Jiang Nanchun (Senior Healthcare Industry Practitioner)

The internet healthcare industry is deeply concerned about the scope and delivery methods of medical services, such as whether consultations are initial or follow-up visits, and whether they rely on physical medical institutions. Indeed, these issues bear on the future trajectory of the industry. Yet, do they not also impact patient experience?

For instance, the development of e-commerce has enabled individuals across diverse socioeconomic strata, geographic regions, income levels, and personal interests to fulfill their needs and experience consumption upgrades.

We certainly have ample reason to believe that the internet can bring about similar transformations in healthcare services. However, the internet healthcare industry has not yet achieved this goal. What we need to consider is whether the industry itself lacks sufficient creativity, or whether it lacks the conditions necessary for innovation.

At the State Council’s regular policy briefing held on April 16, it was disclosed that the “Opinions on Promoting the Development of ‘Internet Plus Healthcare’” had been reviewed and approved by the State Council. The rapid progression from the State Council’s research to the issuance of these opinions underscores the nation’s determination, against the backdrop of the Healthy China 2030 strategy, to drive transformation in the healthcare sector through the internet and new technologies.

Based on the disclosed information, it remains unclear whether internet hospitals are required to have their own physical medical institutions, and how existing internet hospitals will be integrated into a unified management framework with those affiliated with physical hospitals. Further interpretation is awaited upon the official release of the document.

However, the official statement at the press briefing that “initial consultations conducted over the internet are strictly prohibited” has sparked some discussion. In fact, initial consultations via the internet have been in practice in the United States for many years.

On May 27, 2017, Texas Governor Greg Abbott signed the state’s telemedicine legislation (namely Senate Bill SB1107 and House Bill HB2697), repealing the requirement that physicians could only provide telemedicine services after an in-person visit with the patient. Texas thus became the last of the 50 U.S. states to abolish this mandate.

Of course, the practices of others serve only as a reference. However, such approaches do highlight that certain issues concerning internet hospitals still warrant more detailed discussion.

Safety is always the prerequisite for medical practices. Are internet hospitals necessarily less safe than offline consultations?

At the briefing, Yu Xuejun, Director of the Department of Planning and Information under the National Health Commission, stated, “Heaven watches what men do. While internet-based medical and health services or such activities may appear to be conducted invisibly, in reality, the greatest characteristic of the internet is its ability to leave a complete digital trail.”

As Director Yu stated, all diagnostic and treatment activities conducted by internet hospitals are fully recorded and monitored. Coupled with the tamper-proof nature of blockchain technology, this facilitates easy retrospective supervision, potentially enabling more precise regulation than that of physical medical institutions.

Therefore, safety may not depend on whether care is delivered online or offline. With appropriate regulation, safety can be ensured. For example, data from Teladoc, a leading U.S. telemedicine company, shows that over 15 years of development, it has completed more than 2 million consultations, saving users a cumulative $493 million, with no major medical incidents reported.

Regulatory policies need to consider how to be implemented, regarding the regulation that prohibits initial consultations by internet hospitals:

① In practice, how is it determined whether a consultation is an initial visit or a follow-up visit? Is this based on the patient’s self-report or on prior medical records from hospitals? ② Regarding “some relatively mature, stable common and chronic diseases that have been proven effective through domestic and international practice,” who is responsible for interpreting and defining which conditions are eligible for follow-up consultations?

A deeper question arises: with over 4,000 common diseases and more than 7,000 rare diseases in medicine, if the State Council issues a document strongly supporting the development of “Internet + Healthcare,” but only a handful of disease conditions can be covered in implementation, would this significantly diminish the value of the entire policy opinion?

At the State Council policy briefing held on April 16, it was mentioned that internet hospitals mainly operate under two models:

1. Physical medical institutions shall serve as the primary providers, leveraging internet information technology to extend service hours and geographical reach. Internet hospitals shall be registered as the secondary name of these physical institutions, and the services provided by internet hospitals must align with the approved clinical specialties of the corresponding physical medical institutions. 2. Some internet companies and enterprises apply to establish internet hospitals, delivering services to patients by leveraging high-quality expert resources. However, internet hospitals must be anchored to physical medical institutions, and regulatory oversight for online and offline operations must remain consistent.

In short, the provision of online medical consultations and the operation of internet hospitals must still rely on offline physical medical institutions. But what is the underlying logic behind this reliance on physical medical institutions? Is it because there is a need to understand patients’ medical histories, perform physical examinations, and even conduct ancillary tests such as electrocardiograms (ECGs), B-mode ultrasounds, and blood tests?

These measures alone are insufficient; they must be anchored in physical medical institutions. To meet patient needs, internet platforms may choose to collaborate with suitable physical hospitals, health examination centers, and third-party laboratory and imaging centers.

The more significant issue with relying on physical medical institutions is that their core function is treatment-centered. Does this also mean that future “Internet + Healthcare” services will remain treatment-centered?

In fact, since the National Conference on Health and Wellness, China’s healthcare service system has been shifting from a disease-centered model to a health-centered one. If “Internet + Healthcare” remains disease-centered, how can it align with this overarching goal?

If internet hospitals also pursue a health-centric model, relying on physical medical institutions will likewise encounter certain difficulties. This is because the core function of physical medical institutions, particularly hospitals, is disease treatment. Past practices have shown that hospitals have not performed well in preventive care, chronic disease management, and disease rehabilitation, lacking sufficient motivation. Merely shifting to an online platform raises the question of whether it can stimulate hospitals’ enthusiasm for chronic disease management.

Certainly, the competent authorities have also stated that they will introduce administrative measures for internet-based diagnosis and treatment activities as soon as possible, with the hope that these issues can be effectively resolved.