What types of telemedicine services are recognized under Indonesian regulations?

PP Number 28 of 2024 Article 561(1) recognizes three categories of telemedicine services. Teleconsultation, telepharmacy, and other telemedicine services that follow developments in health science and technology. Further details on permissible service types will be regulated by Ministerial Regulation (Article 561(5)). For inter-facility consultations, Permenkes Number 20 of 2019 lists five services: teleradiology, tele-electrocardiography (tele-ECG), tele-ultrasound, clinical teleconsultation, and other telemedicine consultations.

Two Delivery Models and Eligible Facilities

PP 28/2024 Article 558(1) divides telemedicine into inter-facility services and facility-to-public services. Eligible providers include hospitals, Puskesmas, clinics, independent medical or health professional practices, health laboratories, and pharmacies (Article 558(5)). Facilities may operate their own platform or partner with a registered electronic system provider (Article 558(4). Law Number 17 of 2023 Article 172(2)).

Three Categories Under PP 28/2024

Article 561 defines each category. Teleconsultation is remote clinical consultation to assist diagnosis and/or provide management recommendations (Article 561(2)). Telepharmacy is remote pharmaceutical care delivered via communication and information technology (Article 561(3)). The third category covers all other telemedicine consultation services aligned with medical science and technology advances (Article 561(4)). Telemedicine covers clinical services only (Law 17/2023 Article 1 point 22), whereas telehealth covers both clinical and non-clinical services (PP 28/2024 Article 550(2)-(3)).

Inter-Facility Services and Core Requirements

Under Permenkes 20/2019 Article 3(1), teleradiology, tele-ECG, and tele-ultrasound involve sending images. Furthermore, Supporting data from a requesting facility to a consulting facility for specialist expertise (Article 1 point 6). Tele-ultrasound is specifically for obstetric ultrasound (Article 3(4)). Clinical teleconsultation may use text, audio, and/or video (Article 3(6)) and must be recorded in the medical record (Article 3(7)). Consulting providers must be hospitals, while requesting facilities may be hospitals, primary care facilities, or other facilities (Article 6). Under Law 17/2023 Article 453(c), Permenkes 20/2019 remains valid where consistent pending new ministerial rules.

• Licensed Personnel: Inter-facility care requires practitioners with a practice license at the organizing facility (Permenkes 20/2019 Article 2), supported by medical, health. In addition, Support personnel (PP 28/2024 Article 562(1)).
• System Registration and Security: Applications must ensure data security and safety. Furthermore, Self-developed applications must be registered with the Ministry of Health (PP 28/2024 Article 560(1), (3)).
• Electronic Medical Records and Privacy: Telemedicine providers must use electronic medical records (PP 28/2024 Articles 550(1), 552(1). Permenkes 24/2022 Article 4(1)), protect patient data (PP 28/2024 Article 563(5)), and meet infrastructure and clinical standards (Article 558(6)).

Legal basis: PP Number 28 of 2024 Articles 550, 552(1), 558, 560, 561, 562(1), and 563(5). Law Number 17 of 2023 Articles 1 point 22, 172, 453, and 454. Permenkes Number 20 of 2019 Articles 1 point 6, 2, 3, and 6. Permenkes Number 24 of 2022 Article 4(1).