Discussion on the enforcement rule for non-face-to-face trt

Will prescription durations for initial non-face-to-face treatment be limited to 'within 7 days'?…pre-announcement of legislation set for October

Physicians and pharmacists argue, "It must be a supplement to in-person care, a conservative approach is necessary"

Brokerage platforms argue, "We oppose rigid regulatory limits…flexibility is necessary"

As South Korea prepares to formally institutionalize non-face-to-face treatment under the amended Medical Service Act taking effect on Dec. 24, the Ministry of Health and Welfare (MOHW) is preparing a legislative notice for 'Partial Amendment to the Enforcement Rule of the Medical Service Act.'

With the announcement set for early October, intense discussions were underway as of the 28th among the MOHW, medical and pharmaceutical groups, and industry stakeholders over the criteria for core regulations to be included in the enforcement rule.

At the center of the debate are limits on prescription durations for initial non-face-to-face treatment, geographic restrictions, and rules governing off-pharmacy dispensing, including courier delivery standards for prescription drugs.

On prescription limits for initial non-face-to-face treatment, medical and pharmaceutical associations are pushing to limit supply to 'within 7 days.'

Physicians and pharmacists argue that because lawmakers agreed during the review of the Medical Service Act amendment that non-face-to-face treatment would serve strictly as a supplement to in-person care, prescription durations for first-time consultations must be kept as conservative as possible.

Opposing opinions related to introducing the 'Partial Amendment to the Enforcement Rule of the Medical Service Act'. Physicians and pharmacists argue for a conservative approach (limiting supply to 'within 7 days', within the same geographic region where patients are located). In contrast, non-face-to-face treatment brokerage platforms argue for a certain degree of regulatory flexibility (flexibility is needed, must secure patient access to care)

Physicians and pharmacists reason that lowering the barrier for initial non-face-to-face treatment will sharply reduce in-person patient volume, inevitably driving medical institutions to rely heavily on non-face-to-face treatment and ultimately destabilizing the broader healthcare ecosystem.

Non-face-to-face treatment brokerage platforms, however, are pushing back, warning that a '7 days' prescription limit would severely inconvenience non-face-to-face treatment users, undermine patient access to care, and deal a direct operational blow to the brokerage platform sector.

Platform industry representatives argue that, rather than imposing a rigid, across-the-board limit on first-visit prescription days in the enforcement rule, regulators should allow flexibility based on prescribing physicians' clinical discretion to establish a practical non-face-to-face treatment framework.

Furthermore, geographic restrictions on first-time patients, designed to limit nationwide non-face-to-face treatment, represent another major flashpoint. The incoming Medical Service Act stipulates that for initial consultations, patients may only request non-face-to-face treatment within the same geographic region where they are located.

Currently, these geographic boundaries are being defined for initial non-face-to-face treatment at the metropolitan city and provincial level. Most experts believe that allowing patients to receive non-face-to-face treatment only from medical institutions within their own municipality or province is necessary to prevent patients from concentrating at specific providers.

Rules governing off-pharmacy delivery of non-face-to-face treatment prescriptions remain equally contentious. Once non-face-to-face treatment transitions into a permanent program, eligibility for receiving prescribed medications at home via courier or other off-premise methods will be tightly restricted.

Home delivery of prescription medications will be limited to five specific patient groups: residents of islands and remote areas, long-term care insurance beneficiaries, people with disabilities, patients with Class 1 or Class 2 infectious diseases, and rare disease patients. Although the government has expressed willingness to review expanding delivery eligibility for non-face-to-face treatment prescriptions through consultations, substantive talks have yet to take place. Moreover, because broadening prescription drug delivery requires the National Assembly to amend the Pharmaceutical Affairs Act, the prevailing view is that the eligible patient pool for courier delivery is unlikely to expand before the permanent program launches at year-end.

The enforcement rule will specify the geographic boundaries within which these eligible patients can receive home deliveries, a measure aimed at preventing nationwide parcel shipping of prescription drugs.

A daily limit of 25 non-face-to-face treatment prescriptions dispensed per pharmacy is emerging as the most likely standard. Medical institutions will similarly face limits under the enforcement rule capping the proportion of non-face-to-face treatment relative to their total patient care volume.

An official from the medical industry said, "While the non-face-to-face treatment Enforcement Decree did not include regulatory restrictions, the Enforcement Rule encompasses a wide range of regulations, and given the significant difference in opinions between healthcare professional groups and industry players, reaching a consensus will take considerable time."