Guidelines on the Monitoring and Evaluation (M&E) of the Use of Telemedicine in COVID-19 Response

April 14, 2020

DOH-NPC JOINT MEMORANDUM CIRCULAR NO. 2020-0003

 

I. BACKGROUND

Due to the rise of COVID-19 cases in the country and pursuant to Republic Act No. 11332, the President issued Proclamation No. 922, s. 2020 declaring a State of Public Health Emergency throughout the Philippines, and consequently, Proclamation No. 929, s. 2020 placing the entire Luzon under enhanced community quarantine. Simultaneously, a number of local government units (LGUs) have implemented Community Quarantine in their respective jurisdiction.

In the implementation of the Enhanced Community Quarantine, one of the critical measures identified to curb the spread of COVID-19 is the suspension of public transportation. This, however, resulted in missed appointments, missed filling prescriptions, and poor disease management, particularly among individuals with chronic illnesses that require ongoing active care, even when care is readily available.

To help address this gap, under the Joint Memorandum Circular (JMC) # 2020-0001, the Department of Health (DOH) and the National Privacy Commission (NPC) have institutionalized the use of telemedicine as a supplemental and complementary method to enable patients to still receive health services even while staying at home except for serious conditions, emergencies, or to avail of COVID-19-related health services as per standing protocols.

II. OBJECTIVES

The objectives of this Joint Memorandum Circular are to provide actionable information for accountability and performance improvement for telemedicine services, and create evidence for informed decision-making for the DOH and NPC at policy level on the possible long-term use of telemedicine for service delivery. aScITE

III. SCOPE AND COVERAGE

This Joint Memorandum Circular shall apply to the program implementation of telemedicine services during the period of Enhanced Community Quarantine; and shall cover all public and private, national and local healthcare providers regulated by DOH and Philippine Health Insurance Corporation (PhilHealth) providing telemedicine services; DOH-engaged telemedicine partners; the Department of Health; and the National Privacy Commission.

IV. DEFINITION OF TERMS

For the purpose of this Joint Memorandum Circular, the following terms are defined:

1. Evaluation refers to an objective and systematic assessment of an ongoing or completed program to determine its effectiveness, outcomes, impact and sustainability.

2. Healthcare Providers refer to any of the following:

a. Physician refers to all individuals authorized by law to practice medicine pursuant to Republic Act No. 2382, or the "Medical Act of 1959," as amended;

b. Health facility refers to a public or private facility or institution devoted primarily to the provision of services for health promotion, prevention, diagnosis, treatment, rehabilitation and palliation of individuals suffering from illness, disease, injury, disability, or deformity, or in need of medical and nursing care.

3. Monitoring refers to regular and routine collection and analysis of information to track progress of implementation of telemedicine services. It is conducted to ensure that this interim initiative is being implemented in accordance with its intent and to make informed decisions for policy and strategic management.

4. Processing refers to any operation or any set of operations performed upon patient's data including, but not limited to, the collection, recording, organization, storage, updating or modification, extraction, retrieval, consultation, use, consolidation, blocking, submission, erasure or destruction of data; and

5. Telemedicine refers to the practice of medicine by means of electronic and telecommunications technologies such as phone call, chat or short messaging service (SMS), audio- and video-conferencing, among others, to deliver healthcare at a distance between a patient at an originating site, and a physician at a distant site.

6. Telemedicine partner refers to a telemedicine company that has registered with the DOH telemedicine program in COVID-19 response and met the requirements for engagement as set forth under JMC 2020-0001 and its offshoot policies. HEITAD

V. DECLARATION OF PRINCIPLES

The following principles shall govern the implementation of this Joint Memorandum Circular:

1. Results-based. Program management of telemedicine services shall have defined and measurable results that indicate the success of implementation. This contributes to better performance and accountability. It shall focus on activities, outputs, and short-term outcomes.

2. Effectiveness. Evidence of effectiveness, equity and sustainability shall be the basis for long-term use/implementation.

3. Alignment. The results of the monitoring and evaluation shall be interpreted together with existing agency management tools such as the Performance Governance System, and other relevant monitoring and evaluation tools or solutions to ensure strategic alignment and performance improvement.

VI. GUIDELINES

A. Implementation Governance

1. The interagency National eHealth Technical Working Group (NEHTWG) shall set policy directions and program oversight for the implementation of telemedicine services across the country.

2. The NEHTWG shall organize the Sub-Committee on Telemedicine that will: (a) review and monitor the progress of implementation of telemedicine services; (b) conduct the necessary consultations and coordination with concerned stakeholders; and (c) submit monthly assessment and accomplishment reports to the NEHTWG for performance monitoring and evaluation.

• The Sub-Committee on Telemedicine shall be composed of policy and technical experts on telemedicine from relevant agencies and organizations as defined by the NEHTWG.

3. The National eHealth Program Management Office (NEHPMO) in KMITS of the DOH shall act as the overall technical and administrative secretariat for all activities related to the program implementation of telemedicine services. ATICcS

B. Situational Analysis, Goal-Setting and Planning

1. The Sub-Committee on Telemedicine shall prepare strategic and operational plans, and endorse them to the NEHTWG for review and approval.

2. These plans shall include a monitoring and evaluation framework. Initial dimensions for monitoring and evaluation shall be as follows:

a. Outcome measures (safety, effectiveness, efficiency, and quality of care);

b. Performance measures (access, functionality, quality and cost of service);

c. Summary measures (cost comparison); and

d. Operational measures (access, acceptability, provider satisfaction, patient satisfaction, data privacy and cybersecurity).

4. A list of indicators and corresponding targets shall guide implementers to improve performance and results. (Annex 1.0.)

C. Monitoring

1. Healthcare Providers

a. All healthcare providers who have registered with a DOH telemedicine partner shall provide relevant information that will enable the telemedicine partners to provide timely reports to DOH.

b. Any other healthcare providers in telemedicine are encouraged to use secure non-public-facing platforms for the conduct of the teleconsultation while inputting consult data using the DOH data entry platform which can be accessed at telemed.doh.gov.ph. Reports will be extracted by DOH from the platform.

• Required documentation for submission to DOH shall be the signed performance commitment (Annex 2.0).

2. Telemedicine Partners

a. All telemedicine partners shall submit: (1) signed performance commitments; and (2) required documentations and reports to DOH through [email protected] in a timely manner. (Annex 3.0)

b. Telemedicine partners can adopt their own monitoring tools and solutions apart from the DOH requirements.

3. NEHPMO

a. The NEHPMO shall: (i) receive and consolidate all submitted documentations and reports from telemedicine providers and those submitted from the DOH data entry platform; and (ii) provide the Sub-Committee on Telemedicine a summary result of findings and recommendations. TIADCc

b. Feedback from the Sub-Committee on Telemedicine shall result in appropriate and timely action to address issues in program implementation.

4. Sub-Committee on Telemedicine

a. The Sub-Committee shall provide guidance on monitoring and evaluation, and recommend relevant policies to the NEHTWG as necessary.

b. Random audits to verify compliance with applicable DOH and NPC guidelines on the implementation of telemedicine services shall be decided by the Sub-Committee.

D. Evaluation

1. A formative evaluation shall be conducted at an appropriate time.

2. The results of the formative evaluation shall be used to determine if the program is effective in attaining its goals and objectives for COVID-19 response, and consequently, at the policy level on the possible long-term use of telemedicine for service delivery. cSEDTC

VII. REPEALING CLAUSE

All previous issuances that are inconsistent with any provisions of this Joint Memorandum Circular are hereby amended, modified, or repealed accordingly.

VIII. SEPARABILITY CLAUSE

In the event that any provision or part of this Joint Memorandum Circular is declared unauthorized or rendered invalid by any court of law, these provisions not affected by such declaration shall remain valid and in effect.

IX. EFFECTIVITY

This Joint Memorandum Circular shall take effect immediately for the duration of the declared Enhanced Community Quarantine for the management of COVID-19 health situation, and the effectivity of this Order shall likewise be automatically lifted once the imposed quarantine is lifted.

(SGD.) FRANCISCO T. DUQUE III, MD, MScSecretaryDepartment of Health

(SGD.) RAYMUND E. LIBOROPrivacy Commissioner and ChairmanNational Privacy Commission

ANNEX 1.0.

Monitoring and Evaluation Indicators

 

Dimensions	Indicators for Monitoring	Source/Method	Frequency of Collection	Unit Responsible for Monitoring
Outcome & Summary Measures	Output
Average patient satisfaction rating of the telemedicine services provided by the healthcare provider	Submitted telemedicine reports	Monthly	NEHPMO, KMITS
Performance Measures	Input
# of physicians engaged as providers of telemedicine services	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	# of unique individual patients who sought health services through telemedicine per healthcare provider (disaggregation: individual health facility vs. individual physician; daily vs. weekly)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Output
	# of telemedicine consultations received per healthcare provider (disaggregation: companion-assisted patient consultation vs. non-companion-assisted/individual patient consultation; individual health facility vs. individual physician; daily vs. weekly)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Type of telemedicine consultations received per healthcare provider (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician; daily vs. weekly)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Reasons for consultations (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician; daily vs. weekly)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Clinical classification (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Type of disposition per telemedicine consultation received (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
Operational Measures	Input
# of telemedicine providers engaged by DOH	Signed performance commitment & MOA	Weekly	NEHPMO, KMITS
	# of LGUs with engaged telemedicine providers	Signed MOA	Weekly	NEHPMO, KMITS
	# of health facilities engaged per telemedicine provider	Signed performance commitment & MOA	Weekly	NEHPMO, KMITS
	Presence of a Data Protection Officer	Submitted telemedicine reports	One time/as updated	NEHPMO, KMITS
	Privacy policy for telemedicine providers	Telemedicine privacy policy	One time/as updated	NEHPMO, KMITS
	Privacy management program in place of telemedicine providers	Privacy management program implementation plan or privacy manual	One time/as updated	NEHPMO, KMITS
	Activities
	Telemedicine program implementation plan in place for telemedicine providers	Telemedicine program implementation plan	One time/as updated	NEHPMO, KMITS
	Output
	# of patient complaints received by healthcare providers	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	# of patient complaints closed by healthcare providers	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	Types of complaints (i.e., privacy and security breach, medical errors, cost for access, provider disengagement, etc.) — built in monitoring and feedback mechanism in the platform for customer service	Submitted telemedicine reports	Weekly	NEHPMO, KMITS
	# of security incidents and personal data breaches reported within NPC protocols (incident reporting mechanism)	Submitted telemedicine reports	Weekly	NEHPMO, KMITS

 

ANNEX 2.0.

Performance Commitment for Healthcare Providers Who Are Unable to Register with a DOH Telemedicine Partner

(Date)DEPARTMENT OF HEALTHSan Lazaro Compound, Rizal Avenue, Sta. Cruz, Manila

SUBJECT: Performance Commitment

Sir/Madam:

To guarantee our commitment to support the fight against COVID-19, I respectfully submit this Performance Commitment. And for the purposes of this Performance Commitment, I hereby warrant the following representations:

1. That I agree to be enrolled in a sandbox implementation program for the utilization of telemedicine in response to COVID-19. The overall goal is to use telemedicine as a medium to deliver health services to patients in a safe environment following established treatment algorithms and guidelines while utilizing current technology capabilities.

2. That I shall only use a secure platform for medical consultation and referral of patients to the nearest health facility, if necessary.

3. That I shall ensure that the privacy settings of the platform being used is compliant with the minimum legal and regulatory laws and frameworks in the Philippines.

4. That I shall not use public-facing platforms like Youtube or Facebook Live, and such other similar public-facing platforms, for telemedicine consultations.

5. That I shall first obtain the informed consent of the patient prior to the collection of any personal data and the offering of any telemedicine service.

6. That I shall uphold the data privacy rights of patients using the platform, and shall provide mechanisms for the effective exercise of these rights. Patients should be: (a) informed that the platform being used entails privacy risks and that a telehealth consultation may not be equivalent to a face-to-face consult; (b) allowed to discuss their privacy and other related concerns, if any; and (c) be given the option not to proceed with the consult. AaCTcI

7. That I shall ensure that reasonable and appropriate security measures are implemented to safeguard the patients' data collected, used, stored, or otherwise processed using the platform, against any accidental or unlawful destruction, alteration or disclosure as well as unlawful access, fraudulent misuse, or any other unauthorized processing.

7.1. Patients should be informed that any personal data obtained in the course of the consult shall be used for medical treatment, kept confidential, and only those involved in patient's care shall have access.

7.2. That I shall choose a place to conduct the telemedicine consultation beforehand, i.e., conducive to communicating with the patient, and where interruptions or potential unwarranted disclosures are avoided.

8. That I shall comply with all pertinent DOH COVID-19 and non-COVID-19 treatment algorithms and guidelines, including patient surveillance.

9. That I recognize that DOH and I shall be the controller of patients' data, which remains to be owned by the individual patients.

10. That I shall comply with the necessary protocols for data sharing, monitoring and evaluation activities.

11. That I shall render telemedicine services without cost either to the DOH or to the patients receiving the services.

12. That I shall be held liable for any security incident, or privacy violation, or personal data breaches, and other related issues and concerns arising from the conduct of telemedicine consultation, and which are attributable to me or my acts.

13. Nothing in this document shall be interpreted or construed as creating or establishing an Employer-Employee relationship between the DOH and the healthcare provider.

We commit to extending our full support in order to effectively and appropriately deliver primary care teleconsultations to those who are in need.

Very Truly Yours,

_____________________________________________

_____________________________________________

_____________________________________________i.e., address, phone number & email)

_____________________________________________

ANNEX 3.0.

Program Documentations and Reports for Submission by Telemedicine Partners

3.1. Telemedicine Program Implementation Document

 

Minimum Content Requirements	Frequency of Submission
1. Signed performance commitment (telemedicine company)	One-time/As updated
2. Signed performance commitment (for engaged healthcare providers)
3. Accomplished ICT service provider request form
4. Accomplished telemedicine program profile
5. Certified true copy of signed MOA with LGU (if applicable)
6. Telemedicine platform, including data and solutions architecture
7. Health human resource recruitment and management protocol
8. Telemedicine consultation protocol
9. Data privacy and cybersecurity measures
10. Risk and issue management protocol
11. Marketing protocol

 

3.2. Telemedicine Privacy Management Program Document

 

Minimum Content Requirements	Frequency of Submission
1. Contact details of data protection officer	One-time/As updated
2. Privacy policy
3. Documentation of privacy impact assessment
4. Privacy management program implementation plan or privacy manual

 

3.3. Weekly Status Reports (to be submitted every Monday of the following week)

a. Demographics

• Name of telemedicine provider

• Total #, names, and contact details of LGUs engaged

• Total #, names and addresses of health facilities engaged as providers of telemedicine services

• Total #, names and contact details of physicians engaged as providers of telemedicine services

b. Summary of telemedicine consultations

• Total # of unique individual patients who sought health services through telemedicine per healthcare provider per day (disaggregation: individual health facility vs. individual physician)

• Total # of telemedicine consultations received per healthcare provider per day (disaggregation: companion-assisted patient consultation vs. non-companion-assisted/individual patient consultation; individual health facility vs. individual physician)

• Type of telemedicine consultations received per healthcare provider (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)

• Reasons for consultations received per healthcare provider (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)

• Clinical classification (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)

• Type of disposition per telemedicine consultation received (disaggregation: COVID-19 vs. non-COVID-19 health concerns; individual health facility vs. individual physician)

 

Name of Telemedicine Provider:
Name and Address of Health Facility
Name of Physician

Case #

Age

Residence

Date of Consultation

Patient was accompanied by a companion during consultation (Y/N)

Reason for Consultation

COVID-19 Health Concern (Y/N)

Non-COVID-19 Health Concern (Y/N)

Diagnosis

Plan of Management

Issued ePrescription (Y/N)

Issued Referral to Health Facility (Y/N)

Clinical Classification

Disposition

 

c. Feedback

• Average patient satisfaction rating of the telemedicine services provided by the healthcare provider

• # of patient complaints received by healthcare providers

• # of patient complaints closed by healthcare providers

• Types of complaints (i.e., privacy and security breach, medical errors, etc.)

 

Name of Telemedicine Provider:
Name and Address of Health Facility
Name of Physician

Case #	Patient Satisfaction Rating	Complaints/Issues (Y/N)	If yes, nature of complaint.	Action Taken	Closed (Y/N)	If no, indicate reason.

 

• # of telemedicine provider complaints received from healthcare providers

• # of telemedicine provider complaints from healthcare providers closed

• Types of telemedicine provider complaints (i.e., disengagement, etc.)

• # of security incidents and personal data breaches reported within NPC protocols (incident reporting mechanism)

 

Name of Telemedicine Provider:
Total # of LGUs engaged
Total # of health facilities engaged
Total # of physicians engaged

Name of Health Facility	Address	Complaints/Issues (Y/N)	If yes, nature of complaint.	Action Taken	Closed (Y/N)	If no, indicate reason

Name of Physician

Complaints/Issues (Y/N)

If yes, nature of complaint.

Action

Closed (Y/N)

If no, indicate reason

 

3.4. Performance Commitment for DOH Telemedicine Partners

(Letterhead of Telemedicine Company)

(Date)DEPARTMENT OF HEALTHSan Lazaro Compound, Rizal Avenue. Sta. Cruz, Manila

SUBJECT: Performance Commitment

Sir/Madam:

To guarantee our commitment to support the fight against COVID-19, we respectfully submit this Performance Commitment. And for the purposes of this Performance Commitment, we hereby warrant the following representations:

1. That we agree to be enrolled in a sandbox implementation program for the utilization of telemedicine in response to COVID-19 where telemedicine companies are enjoined to conform to a minimum set of standard regulation for the practice of telemedicine. The overall goal is to test telemedicine as a medium to deliver care to individuals in a safe environment, utilizing current technology capabilities.

2. That we are a duly recognized telemedicine company abiding by the legal and regulatory framework of the country.

3. That all professional health care providers in our company possess proper credentials and given appropriate privileges in accordance with our policies and procedures.

4. That we shall render telemedicine services without cost either to the Department of Health or to the patients receiving the services.

5. That we shall ensure that all operations are compliant with all appropriate legal and regulatory frameworks in the Philippines.

6. That we shall provide a mechanism for physicians or medical doctors to sign up for this initiative and in the interim, for the latter to volunteer their medical services to the public at no charge to the patient.

7. That we shall provide a form of safety assurance for physicians to operate Telemedicine services to the patients or individuals.

8. That we shall provide a secure and user-friendly platform which shall be made available for medical consultation. The physicians or medical doctors will be able to make use of the process of this platform to record and maintain patient data and refer the patient to the nearest health facility, if necessary. HESIcT

9. That we shall ensure that reasonable and appropriate security measures are implemented to safeguard the patients' and doctors' data collected, used, stored, or otherwise processed using the platform, against any accidental or unlawful destruction, alteration or disclosure as well as unlawful access, fraudulent misuse, or any other unauthorized processing.

10. That we shall train volunteer physicians to handle telemedicine consultations.

11. That we shall first obtain the informed consent of the patient prior to the collection of any personal data and the offering of any telemedicine service.

12. That we shall uphold the data privacy rights of patients and physicians or medical doctors using the platform, and shall provide mechanisms for the effective exercise of these rights.

13. That we shall comply with all pertinent DOH guidelines on COVID-19 responses and patient surveillance.

14. That we recognize that the DOH shall be the controller of patients' data, which remains to be owned by the individual patients.

15. That we shall comply with the necessary protocols for data sharing, monitoring and evaluation activities.

16. That we shall act as the processor of patient data for and on behalf of the DOH.

17. That we shall be held liable for any security incident, or privacy violations, or personal data breaches, and other related issues and concerns arising from the use of our platform, and which are attributable to our platform or our company.

18. Nothing in this document shall be interpreted or construed as creating or establishing an Employer-Employee relationship between the DOH and telemedicine partner.

We commit to extending our full support in order to effectively and appropriately deliver primary care teleconsultations to those who are in need.

Very Truly Yours,

_______________________________________________

3.5. Performance Commitment for Engaged Healthcare Providers by DOH Telemedicine Partners

(Date)DEPARTMENT OF HEALTHSan Lazaro Compound, Rizal Avenue, Sta. Cruz, Manila

SUBJECT: Performance Commitment

Sir/Madam:

To guarantee our commitment to support the fight against COVID-19, I respectfully submit this Performance Commitment. And for the purposes of this Performance Commitment, I hereby warrant the following representations:

1. That I agree to be enrolled in a sandbox implementation program for the utilization of telemedicine in response to COVID-19. The overall goal is to use telemedicine as a medium to deliver health services to patients in a safe environment following established treatment algorithms and guidelines while utilizing current technology capabilities.

2. That I shall only use a secure platform for medical consultation and referral of patients to the nearest health facility, if necessary.

3. That I shall ensure that the privacy settings of the platform being used is compliant with the minimum legal and regulatory laws and frameworks in the Philippines. caITAC

4. That I shall not use public-facing platforms like Youtube or Facebook Live, and such other similar public-facing platforms, for telemedicine consultations.

5. That I shall first obtain the informed consent of the patient prior to the collection of any personal data and the offering of any telemedicine service.

6. That I shall uphold the data privacy rights of patients using the platform, and shall provide mechanisms for the effective exercise of these rights. Patients should be: (a) informed that the platform being used entails privacy risks and that a telehealth consultation may not be equivalent to a face-to-face consult; (b) allowed to discuss their privacy and other related concerns, if any; and (c) be given the option not to proceed with the consult.

7. That I shall ensure that reasonable and appropriate security measures are implemented to safeguard the patients' data collected, used, stored, or otherwise processed using the platform, against any accidental or unlawful destruction, alteration or disclosure as well as unlawful access, fraudulent misuse, or any other unauthorized processing.

7.1. Patients should be informed that any personal data obtained in the course of the consult shall be used for medical treatment, kept confidential, and only those involved in patient's care shall have access.

7.2. That I shall choose a place to conduct the telemedicine consultation beforehand, i.e., conducive to communicating with the patient, and where interruptions or potential unwarranted disclosures are avoided.

8. That I shall comply with all pertinent DOH COVID-19 and non-COVID-19 treatment algorithms and guidelines, including patient surveillance.

9. That I recognize that DOH and I shall be the controller of patients' data, which remains to be owned by the individual patients.

10. That I shall comply with the necessary protocols for data sharing, monitoring and evaluation activities.

11. That I shall render telemedicine services without cost either to the DOH or to the patients receiving the services.

12. That I shall be held liable for any security incident, or privacy violation, or personal data breaches, and other related issues and concerns arising from the conduct of telemedicine consultation, and which are attributable to me or my acts.

13. Nothing in this document shall be interpreted or construed as creating or establishing an Employer-Employee relationship between the telemedicine partner and healthcare provider, and between the DOH and the healthcare provider.

We commit to extending our full support in order to effectively and appropriately deliver primary care teleconsultations to those who are in need. ICHDca

Very Truly Yours,

_____________________________________________

_____________________________________________

_____________________________________________i.e., address, phone number & email)

3.6. ICT Solutions Provider Request Form

 

3.7 Telemedicine Program Template

Telemedicine Program Profile

ANNEX 4.0.

Recommended Templates

4.1 Clinical Abstract/Consultation Summary Template

 

4.2 Patient Satisfaction Survey Form

 

4.3. Sample Informed Consent