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F.A.Q.s Regarding CRMC's Privacy Regulations and the Application of the Health Information Act 2000 in Particular and Unusual Situations

1) Can I text-message with my patient as a form of virtual consultation?

CRMC's approach to virtual consultation is to always keep them as a very last option, and to resort to them only when it is not possible to see the patient in person. Starting from 2022, it is advisable to PCPs at CRMC to couple virtual visits where a patient should receive a physical examination, with an RN visit to the patient's home. The RN can carry out a thorough physical examination and report findings back to the physician for further decision-making. This option is unique to CRMC and it is there to reduce chances of misdiagnosis, mismanagement, and allegations of professional negligence, which often characterize virtual consultations.

If you choose to consult a patient via text-message, this must never be done via simple SMS. Normal text messages are not encrypted and may be intercepted. By using SMS services, you put your patient's personal information at risk. CRMC currently approves only two systems for secure, private, and end-to-end encrypted services: Signal and Threema. These two services cannot be hacked. If you choose to use the first one (Signal), you will automatically provide your patient with your private mobile phone number. If you choose the second service (Threema), your telephone number will remain secure and it will not be shared with your patient. Only a personalized code will be shared with them. Signal allows for video consultations. Threema currently supports only voice calls. Both services may be used on your desktop as well as on your phone.

No other services are approved by CRMC for texting or video consulting patients or for sharing files with them.

2) Is there a particular procedure that I should follow before consulting a patient over the phone?

Yes. CRMC's policies are designed to reduce legal risks for patients and for practitioners. According to the current rules in place at CRMC for best and safest practice, before consulting a patient over the phone (no matter who initiated the call), the physician or the nurse must validate the identity of the patient by having the patient confirming their date of birth and full address. If a patient is unable to validate one of these two data, the consultation should not happen. If a patient is cognitively impaired, for example, it is definitely not safe for the physician or the nurse to make decisions about the patient's care over a phone consultation.


3) Can I still consult a patient virtually if I suspect that they may have cognitive impairment?

CRMC strongly advises clinicians against consulting patient virtually if you suspect that your patient's cognition may be impaired. Please, also remember that patients with cognitive impairment may be coerced into doing something they normally would not want to do. Your conversation may be overheard by another party who could have coerced the patient into allowing them to be present.

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