Teleradiology (Teleradiologi) under Permenkes 20/2019 and Law 17/2023

Permenkes 20/2019 Article 3(2) defines Teleradiology (Teleradiologi) as a diagnostic radiology service using electronic transmission of images from all radiology modalities and supporting data. The transmission is sent from a Requesting Health Facility to a Consulting Health Facility to obtain Expertise for establishing a diagnosis. Under Article 1(6), Expertise is the specialist physician's or relevant expert's analysis and conclusion on the radiological image.

Position in the Regulations

Permenkes 20/2019 lists teleradiology as the first type of inter-facility telemedicine (Article 3(1)(a)). Newer statutory umbrellas are Law Number 17 of 2023 on Health Article 172(3)(a) and PP Number 28 of 2024 Article 558(2) on inter-facility telemedicine. Although Law 17/2023 Article 454(d) repealed Law 36/2009, Article 453(c) keeps implementing regulations of Law 36/2009 in force where consistent.

Parties Involved and Practical Requirements

The requesting facility may be a hospital, first-level facility, or other health facility (Article 6(3)). At the same time, The consulting provider is a hospital (Article 6(1)) where specialist physicians, subspecialists. Alternatively, Other health experts issue the reading (Article 9(2)–(3)). Under Article 14(3)–(4), the reading must state at least the requesting doctor's name, the reading specialist's name, patient identity. In addition, Required notes, and it must be printable as part of the patient's medical record. Both facilities must safeguard patient data confidentiality (Articles 17(2)(b), 18(2)(b)).

Related terms: Tele-electrocardiography, tele-ultrasonography (limited to obstetric ultrasound under Article 3(4)), and clinical teleconsultation (Article 3(1)(b)–(e)).

Legal basis: Permenkes Number 20 of 2019 Articles 1(6), 3, 6, 9(2)–(3), 14(3)–(4), 17(2)(b), and 18(2)(b). Law Number 17 of 2023 Articles 172(3)(a), 453(c), and 454(d). PP Number 28 of 2024 Article 558(2).